Guaranty Trust Co. v. Commissioner
United States Board of Tax Appeals
Where a residuary estate is left to charity, but subject to taxes, other charges, and annuities such as are a charge upon the whole estate and not taxable to the beneficiaries, the fiduciary may not deduct from gross income, as amount paid to or permanently set aside for charitable uses, the amounts paid the annuitants.
1Opinion of the Court
opinion.
Goodrich::
Respondent determined deficiencies in income tax of $13,963.09 for 1929 and $14,339.94 for 1930, resulting from his refusal to allow as deductions from the estate’s-income for these years $94,500 and $92,694.14, respectively, being the amounts paid pursuant to will to various annuitants, except decedent’s widow.. In these proceedings, which upon motion were consolidated, petitioner assails respondent’s determinations as erroneous on the ground that the payments to the annuitants should be deducted from the income of the estate, under the provision of section 162 (a), Revenue…
2Cases cited6 opinions
- Helvering v. ButterworthSupreme Court of the United States · 1933
- Burnet v. WhitehouseSupreme Court of the United States · 1931
- De Reuter v. CommissionerUnited States Board of Tax Appeals · 1927
- Boston Safe Deposit & Trust Co. v. CommissionerUnited States Board of Tax Appeals · 1932
- Pitman v. CommissionerUnited States Board of Tax Appeals · 1931
1 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- Pallottini v. CommissionerUnited States Tax Court · 1988
- Estate of Ford v. CommissionerUnited States Tax Court · 1993
- Union Trust Co. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1940
- Old Colony Trust Co. v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1936
- Wicker v. CommissionerUnited States Tax Court · 1993
2 more not listed; retrieve them via the Exa API.