Archbold v. Commissioner
United States Board of Tax Appeals
1. The amount allowable as a deduction under section 403(a)(2) of the Revenue Act of 1921 should not be reduced by the amount allowable as deductions under section 403(a)(1) and (3) or any part thereof where one bank account is maintained in which is deposited funds received from the sale of prior-taxed property and funds received from other sources and payments are made therefrom which give rise to the deductions under section 403(a)(1) and (3), provided the latter funds…
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1. The amount allowable as a deduction under section 403(a)(2) of the Revenue Act of 1921 should not be reduced by the amount allowable as deductions under section 403(a)(1) and (3) or any part thereof where one bank account is maintained in which is deposited funds received from the sale of prior-taxed property and funds received from other sources and payments are made therefrom which give rise to the deductions under section 403(a)(1) and (3), provided the latter funds are always sufficient to pay the amounts which are allowable as deductions under section 403(a)(1) and (3). 2. The value…
1Opinion of the Court
*925OPINIOH.
Littleton:
The following contentions are advanced by the executor:
1. That he should be allowed as a deduction in establishing the net taxable estate the sum oí $501,690.14 expended for items deductible under section 403 (a) (1) and (3) of the Revenue Act of 1921 and that no part of said sum was paid with the proceeds of the sale of prior-taxed property as claimed by the Commissioner.
2. That securities aggregating $237,432.31 in value at the date of the decedent’s death, and bought with the proceeds of the sale of prior-taxed property, should be deducted as acquired in exchange for…
2Cases cited11 opinions
- Eisner v. MacOmberSupreme Court of the United States · 1920
- Gould v. GouldSupreme Court of the United States · 1917
- United States v. PhellisSupreme Court of the United States · 1921
- Southern Pacific Co. v. LoweSupreme Court of the United States · 1918
- Gibbons v. MahonSupreme Court of the United States · 1890
6 more not listed; retrieve them via the Exa API.
3Cited by3 opinions
- Archbold v. CommissionerUnited States Board of Tax Appeals · 1927
- Northern Trust Co. v. CommissionerUnited States Board of Tax Appeals · 1928
- Rolfe v. CommissionerUnited States Board of Tax Appeals · 1929