Bell v. Commissioner
United States Board of Tax Appeals
The entire consideration in cash and its equivalent paid to the respective petitioners by the remainderman, their son, for their life interests in parallel trusts they had previously created, held, taxable as ordinary income.
1Opinion of the Court
*488OPINION.
OppeR :
It is not open to question that the interest of a life tenant limited to the right to receive income is taxable in full as such. Irwin v. Gavit, 268 U. S. 161. The Court there found “no doubt in our minds that if a fund were given to trustees for A for life with remainder over, the income received by the trustees and paid over to A would be income of A under the statute.” The question we have to decide is whether the price paid in one sum for that interest, arrived at by the parties for all practical purposes by computing the present value of a life estate for the life of a…
2Cases cited5 opinions
- Blair v. CommissionerSupreme Court of the United States · 1937
- Harrison v. SchaffnerSupreme Court of the United States · 1941
- Irwin v. GavitSupreme Court of the United States · 1925
- Hort v. CommissionerSupreme Court of the United States · 1941
- Maass v. HigginsSupreme Court of the United States · 1941
3Cited by17 opinions
- McAllister v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1946
- Cuddihy v. CommissionerUnited States Tax Court · 1959
- Bell's Estate v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1943
- Bell v. Harrison. Bell v. United StatesCourt of Appeals for the Seventh Circuit · 1954
- Crocker v. CommissionerUnited States Tax Court · 1962
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