Fidelity-Philadelphia Trust Co. v. Commissioner
United States Board of Tax Appeals
1. Where the widow elected to take under decedent's will in lieu of dower, held that income of the trust estate paid over to the widow during the taxable years in accordance with the terms of the will is not deductible as a distribution of income to a beneficiary, within the provisions of section 219(b)(2) of the Revenue Act of 1926. Julia Butterworth et al., Trustees,23 B.T.A. 838, followed. 2. Where one-third of the corpus of the trust estate was, by the terms of…
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1. Where the widow elected to take under decedent's will in lieu of dower, held that income of the trust estate paid over to the widow during the taxable years in accordance with the terms of the will is not deductible as a distribution of income to a beneficiary, within the provisions of section 219(b)(2) of the Revenue Act of 1926. Julia Butterworth et al., Trustees,23 B.T.A. 838, followed. 2. Where one-third of the corpus of the trust estate was, by the terms of decedent's will, given to charitable institutions after the widow's death, but during her lifetime the income was payable to her,…
1Opinion of the Court
FIDELITY-PHILADELPHIA TRUST COMPANY, TRUSTEE UNDER THE WILL OF WILLIAM L. DUBOIS, DECEASED, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Fidelity-Philadelphia Trust Co. v. Commissioner
Docket Nos. 48492, 51669.
United States Board of Tax Appeals
25 B.T.A. 1359; 1932 BTA LEXIS 1385;
April 30, 1932, Promulgated
1. Where the widow elected to take under decedent's will in lieu of dower, held that income of the trust estate paid over to the widow during the taxable years in accordance with the terms of the will is not deductible as a distribution of income to a beneficiary, within the…
2Cases cited2 opinions
- Butterworth v. CommissionerUnited States Board of Tax Appeals · 1931
- Fidelity-Philadelphia Trust Co. v. CommissionerUnited States Board of Tax Appeals · 1932