Housman v. Commissioner
United States Board of Tax Appeals
1. Held, the bequest of income to taxpayer for life was not subject to a trust, in favor of a son, of part thereof. Payments made to the son were not payments under the will and were gifts from taxpayer. 2. Held, the facts do not show a contract between taxpayer and her deceased husband at the time of the execution of his last will and testament under which their son was a third party beneficiary. 3. Held, compromise agreement between petitioner and her son in 1928, whereby…
Read the full summary
1. Held, the bequest of income to taxpayer for life was not subject to a trust, in favor of a son, of part thereof. Payments made to the son were not payments under the will and were gifts from taxpayer. 2. Held, the facts do not show a contract between taxpayer and her deceased husband at the time of the execution of his last will and testament under which their son was a third party beneficiary. 3. Held, compromise agreement between petitioner and her son in 1928, whereby the son forebore suing taxpayer, his mother, if she would periodically transfer to him stipulated sums, was "for less…
1Opinion of the Court
STELLA S. HOUSMAN, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Housman v. Commissioner
Docket Nos. 81300, 83346.
United States Board of Tax Appeals
38 B.T.A. 1007; 1938 BTA LEXIS 800;
October 25, 1938, Promulgated
1. Held, the bequest of income to taxpayer for life was not subject to a trust, in favor of a son, of part thereof. Payments made to the son were not payments under the will and were gifts from taxpayer.
2. Held, the facts do not show a contract between taxpayer and her deceased husband at the time of the execution of his last will and testament under which their son was a…
2Cases cited25 opinions
- Brushaber v. Union Pacific RailroadSupreme Court of the United States · 1916
- Blodgett v. HoldenSupreme Court of the United States · 1927
- A. Magnano Co. v. HamiltonSupreme Court of the United States · 1934
- Untermyer v. AndersonSupreme Court of the United States · 1928
- Trustees of Amherst College v. RitchNew York Court of Appeals · 1897
20 more not listed; retrieve them via the Exa API.