County Nat'l Bank & Trust Co. v. Commissioner
United States Board of Tax Appeals
A capital loss sustained by an estate in the process of administration is personal to the estate as a taxable entity, and a sole devisee and legatee receiving the income of the estate in 1933 in the form of interest and dividends may not deduct from such income any part of the capital loss.
1Opinion of the Court
COUNTY NATIONAL BANK AND TRUST COMPANY OF SANTA BARBARA, EXECUTOR OF THE LAST WILL AND TESTAMENT OF RALPH ISHAM, DECEASED, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
County Nat'l Bank & Trust Co. v. Commissioner
Docket No. 89211.
United States Board of Tax Appeals
39 B.T.A. 357; 1939 BTA LEXIS 1040;
February 9, 1939, Promulgated
A capital loss sustained by an estate in the process of administration is personal to the estate as a taxable entity, and a sole devisee and legatee receiving the income of the estate in 1933 in the form of interest and dividends may not deduct from such…
2Cases cited10 opinions
- Freuler v. HelveringSupreme Court of the United States · 1934
- Merchants' Loan & Trust Co. v. SmietankaSupreme Court of the United States · 1921
- Anderson v. WilsonSupreme Court of the United States · 1933
- Keith v. JohnsonSupreme Court of the United States · 1926
- Baltzell v. MitchellCourt of Appeals for the First Circuit · 1925
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