Fullerton v. Commissioner
United States Tax Court
Trust formed to hold property on behalf of former corporate shareholders pending discharge of mortgage liability thereon held, on facts, not conducting business and hence not taxable as a corporation so as to result in realization of capital gain by beneficiary upon termination of trust.
1Opinion of the Court
George I. Fullerton, Petitioner, v. Commissioner of Internal Revenue, Respondent
Fullerton v. Commissioner
Docket No. 38572
United States Tax Court
22 T.C. 372; 1954 U.S. Tax Ct. LEXIS 199;
May 21, 1954, Filed. May 21, 1954, Filed
Decision will be entered under Rule 50.
Trust formed to hold property on behalf of former corporate shareholders pending discharge of mortgage liability thereon held, on facts, not conducting business and hence not taxable as a corporation so as to result in realization of capital gain by beneficiary upon termination of trust.
Warren F. Wattles, Esq., for the petitioner.
Stan…
2Cases cited8 opinions
- Morrissey v. CommissionerSupreme Court of the United States · 1935
- A. A. Lewis & Co. v. CommissionerSupreme Court of the United States · 1937
- Garrett v. United StatesUnited States Court of Claims · 1954
- Commissioner of Internal Revenue v. Chase Nat. BankCourt of Appeals for the Second Circuit · 1941
- Estate of Ferber v. CommissionerUnited States Tax Court · 1954
3 more not listed; retrieve them via the Exa API.