Legal Opinion

Bedell v. Commissioner

United States Tax Court

Decided June 18, 1986No. Docket Nos. 21381-84, 21382-84Published

Held, the testamentary trust herein did not have "associates", and therefore could not be classified as an "association" taxable as a corporation. Sec. 7701(a)(3), I.R.C. 1954; sec. 301.7701-2(a)(2) and (3), Proced. & Admin. Regs.

1Opinion of the Court

Estate of Harry M. Bedell, Sr., Trust, Helen Bedell Stamer and Harry M. Bedell, Jr., Trustees, Petitioner v. Commissioner of Internal Revenue, Respondent

Bedell v. Commissioner

Docket Nos. 21381-84, 21382-84

United States Tax Court

86 T.C. 1207; 1986 U.S. Tax Ct. LEXIS 94; 86 T.C. No. 70;

June 18, 1986, Filed

Decision will be entered under Rule 155.

Held, the testamentary trust herein did not have "associates", and therefore could not be classified as an "association" taxable as a corporation. Sec. 7701(a)(3), I.R.C. 1954; sec. 301.7701-2(a)(2) and (3), Proced. & Admin. Regs.

K. Martin Worthy,…

2Cases cited12 opinions

  1. Morrissey v. CommissionerSupreme Court of the United States · 1935
  2. Helvering v. Coleman-Gilbert AssociatesSupreme Court of the United States · 1935
  3. Swanson v. CommissionerSupreme Court of the United States · 1935
  4. Foster v. Comm'rUnited States Tax Court · 1983
  5. Helvering v. CombsSupreme Court of the United States · 1935

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