Legal Opinion
Burchenal v. Commissioner
Court of Appeals for the Sixth Circuit
Decided July 2, 1945No. 9935PublishedCited by 5 opinions
1Opinion of the Court
ALLEN, Circuit Judge.
The petitioner attacks a decision of the Tax Court which denied certain deductions claimed under § 162(c) of the Internal Revenue Code, 26 U.S.C.A. Int.Rev.Code, § 162(c), for amounts distributed by the executor of an estate to himself as testamentary trustee. The estate was in process of administration during the taxable years 1939 and 1940. Under the authority of the will the petitioner as executor designated himself as trustee of the residuary trust established by the will for the benefit of the decedent’s five adult children. In accordance with the terms of the will…
2Cases cited12 opinions
- Dobson v. CommissionerSupreme Court of the United States · 1944
- Helvering v. ButterworthSupreme Court of the United States · 1933
- Burnet v. WhitehouseSupreme Court of the United States · 1931
- Commissioner v. Estate of BedfordSupreme Court of the United States · 1945
- Richardson v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1941
7 more not listed; retrieve them via the Exa API.
3Cited by5 opinions
- Commissioner of Internal Revenue v. Mildred Irene SiegelCourt of Appeals for the Ninth Circuit · 1957
- Carlisle v. CommissionerCourt of Appeals for the Sixth Circuit · 1948
- Dunlop v. CommissionerCourt of Appeals for the Eighth Circuit · 1948
- Simon v. HoeyDistrict Court, S.D. New York · 1949
- Smith's Estate v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1948