Malcom v. Commissioner
United States Board of Tax Appeals
The petitioner is the sole life income beneficiary of a trust which in 1932 and 1933 received $10,443.25 and $2,346.91, respectively, as "annual consideration payments" for granting a lease beginning in 1941 on certain property owned by the trust.
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The petitioner is the sole life income beneficiary of a trust which in 1932 and 1933 received $10,443.25 and $2,346.91, respectively, as "annual consideration payments" for granting a lease beginning in 1941 on certain property owned by the trust. The trust did not pay over to the petitioner in either 1932 or 1933 the payments referred to, but held them as undistributed income to be paid to the petitioner in 1941, or to whomsoever might be entitled to receive them upon the prior termination of the trust. Held, that the payments constituted currently distributable income of the trust taxable…
1Opinion of the Court
THALIA W. MALCOM, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Malcom v. Commissioner
Docket Nos. 81192, 82651.
United States Board of Tax Appeals
36 B.T.A. 358; 1937 BTA LEXIS 731;
July 20, 1937, Promulgated
The petitioner is the sole life income beneficiary of a trust which in 1932 and 1933 received $10,443.25 and $2,346.91, respectively, as "annual consideration payments" for granting a lease beginning in 1941 on certain property owned by the trust. The trust did not pay over to the petitioner in either 1932 or 1933 the payments referred to, but held them as undistributed income…
2Cases cited1 opinion
- Malcom v. CommissionerUnited States Board of Tax Appeals · 1937