Hopkins v. Commissioner
United States Tax Court
1. Held, in Docket No. 12817, that amounts received annually by a beneficiary of a trust were received in partial payment of an indebtedness of the grantor of the trust to that beneficiary and were not taxable to the beneficiary under section 162 (b) of the Internal Revenue Code; held, further, that no part of such amounts was taxable to such beneficiary as an annuity under section 22 (a) (2) (A) of the Internal Revenue Code. 2. Held, in Docket No. 12818, that petitioner…
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1. Held, in Docket No. 12817, that amounts received annually by a beneficiary of a trust were received in partial payment of an indebtedness of the grantor of the trust to that beneficiary and were not taxable to the beneficiary under section 162 (b) of the Internal Revenue Code; held, further, that no part of such amounts was taxable to such beneficiary as an annuity under section 22 (a) (2) (A) of the Internal Revenue Code. 2. Held, in Docket No. 12818, that petitioner trust therein is entitled to a deduction from its gross income of an amount of capital gain realized in 1943 as an amount…
1Opinion of the Court
OPINION.
Tyson, Judge:
In Docket No. 12817 respondent determined, for the year 1943, a deficiency in income and victory tax of $11,320.66 against petitioner Lydia Hopkins, and in Docket No. 12818 he determined, for the year 1943, a deficiency in income and victory tax of $13,794.75 against petitioner Mary K. Hopkins Trust No. 5991, Wells Fargo Bank & Union Trust Co., trustee. Each petitioner seeks re-determination of the deficiency determined against her or it. The proceedings have been consolidated.
The issue in Docket No. 12817 is whether the amount of $24,000, or any portion thereof, paid…
2Cases cited6 opinions
- Lyeth v. HoeySupreme Court of the United States · 1938
- Irwin v. GavitSupreme Court of the United States · 1925
- Helvering v. ButterworthSupreme Court of the United States · 1933
- Burnet v. WhitehouseSupreme Court of the United States · 1931
- Whitehead v. CommissionerUnited States Tax Court · 1944
1 more not listed; retrieve them via the Exa API.
3Cited by17 opinions
- Lare v. CommissionerUnited States Tax Court · 1974
- Milleg v. CommissionerUnited States Tax Court · 1952
- Leon A. Beeghly Fund v. CommissionerUnited States Tax Court · 1960
- Williams v. CommissionerUnited States Tax Court · 1961
- Díaz Danuz v. Secretario de HaciendaSupreme Court of Puerto Rico · 1964
12 more not listed; retrieve them via the Exa API.