Kuldell v. Commissioner
United States Board of Tax Appeals
Dividends declared by a solvent corporation upon stock held by an estate during administration and prior to any distribution, constitute taxable income to the estate. Held, further, since ultimate beneficiaries were not tax-exempt person, assignments of their interests in the residuary estate did not affect the status of the dividends as income to the estate.
1Opinion of the Court
*802OPINION.
Smith:
Among the assets of the decedent’s estate were 1,500 shares of stock of the Hughes Tool Company, which the facts show would ultimately be distributed to the residuary legatees, since the estate otherwise seems to have been sufficient for the payment of decedent’s debts, expenses of administration, etc. One-half of the residuary estate was left to the decedent’s son and the other half to decedent’s father, mother, and brother in equal shares. On or about May 28, 1924, the father, mother, and brother sold their interests in the decedent’s estate (with an exception not material…
2Cases cited18 opinions
- Brewster v. GageSupreme Court of the United States · 1930
- Lederer v. StocktonSupreme Court of the United States · 1922
- Wager v. . WagerNew York Court of Appeals · 1882
- Henry v. United StatesSupreme Court of the United States · 1920
- United States v. JonesSupreme Court of the United States · 1915
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3Cited by7 opinions
- Petersen v. CommissionerUnited States Tax Court · 1961
- Kuldell v. CommissionerCourt of Appeals for the Fifth Circuit · 1934
- Varnell v. CommissionerUnited States Board of Tax Appeals · 1933
- Grimm v. CommissionerUnited States Tax Court · 1987
- Grimm v. CommissionerUnited States Tax Court · 1987
2 more not listed; retrieve them via the Exa API.