Francis v. Commissioner
United States Board of Tax Appeals
1. Petitioners were remaindermen under a declaration of trust of personalty made originally in 1892. The life tenant died March 3, 1921, and under state law petitioners became at once entitled and the trust ceased except for the power of the trustee to sell. The trustee thereafter sold and distributed the proceeds.
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1. Petitioners were remaindermen under a declaration of trust of personalty made originally in 1892. The life tenant died March 3, 1921, and under state law petitioners became at once entitled and the trust ceased except for the power of the trustee to sell. The trustee thereafter sold and distributed the proceeds. Held, the sale resulted in gain or loss to petitioners and the basis thereof is the value of property sold when legally acquired on March 3, 1921. 2. Section 202(a)(2), providing the basis for ascertaining gain or loss on the sale of property acquired by gift after December 31,…
1Opinion of the Court
FRANCIS FRANCIS, GUARDIAN OF FRANCIS FRANCIS, JR., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
EVELYN FRANCIS FANE, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Francis v. Commissioner
Docket Nos. 16724, 16725.
United States Board of Tax Appeals
15 B.T.A. 1332; 1929 BTA LEXIS 2683;
April 10, 1929, Promulgated
1. Petitioners were remaindermen under a declaration of trust of personalty made originally in 1892. The life tenant died March 3, 1921, and under state law petitioners became at once entitled and the trust ceased except for the power of the trustee to sell. The…
2Cases cited9 opinions
- United States v. FlannerySupreme Court of the United States · 1925
- Taft v. BowersSupreme Court of the United States · 1929
- McCaughn v. LudingtonSupreme Court of the United States · 1925
- Cochrane v. . SchellNew York Court of Appeals · 1894
- Brown v. RichterAppellate Division of the Supreme Court of the State of New York · 1898
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