Burgwin v. Commissioner
United States Tax Court
Petitioner is the life beneficiary of a testamentary trust. The trustee surrendered 110 shares of stock of the Union Trust Company of Pittsburgh in exchange for 880 shares of stock of the Mellon National Bank and Trust Company pursuant to a tax-free exchange of stock for stock on reorganization. The trustees allocated the 880 shares received in the exchange to corpus.
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Petitioner is the life beneficiary of a testamentary trust. The trustee surrendered 110 shares of stock of the Union Trust Company of Pittsburgh in exchange for 880 shares of stock of the Mellon National Bank and Trust Company pursuant to a tax-free exchange of stock for stock on reorganization. The trustees allocated the 880 shares received in the exchange to corpus. Petitioner filed exceptions to the account of the trustees and brought an unsuccessful suit in the courts of Pennsylvania, claiming that 509 shares of stock should be distributed to her as income. Held, petitioner is entitled…
1Opinion of the Court
Adelaide D. J. Burgwin, Petitioner, v. Commissioner of Internal Revenue, Respondent
Burgwin v. Commissioner
Docket No. 66160
United States Tax Court
31 T.C. 981; 1959 U.S. Tax Ct. LEXIS 242;
February 11, 1959, Filed
Decision will be entered under Rule 50.
Petitioner is the life beneficiary of a testamentary trust. The trustee surrendered 110 shares of stock of the Union Trust Company of Pittsburgh in exchange for 880 shares of stock of the Mellon National Bank and Trust Company pursuant to a tax-free exchange of stock for stock on reorganization. The trustees allocated the 880 shares received in the…
2Cases cited12 opinions
- Plunkett v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1941
- Beck v. CommissionerUnited States Tax Court · 1950
- McFaddin v. CommissionerUnited States Tax Court · 1943
- Helvering v. StormfeltzCourt of Appeals for the Eighth Circuit · 1944
- Plunkett v. CommissionerUnited States Board of Tax Appeals · 1940
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