Estate of Bryan v. Commissioner
United States Tax Court
James and Mary Bryan were equal partners in Bryan Rock and Sand Company, engaged in the quarrying business, prior to James' death in 1953. Under James' will he appointed a bank executor of his estate with directions to pay all obligations and then bequeathed the residue of his estate to the bank, as trustee, to pay the net income therefrom to Mary for life.
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James and Mary Bryan were equal partners in Bryan Rock and Sand Company, engaged in the quarrying business, prior to James' death in 1953. Under James' will he appointed a bank executor of his estate with directions to pay all obligations and then bequeathed the residue of his estate to the bank, as trustee, to pay the net income therefrom to Mary for life. The will also directed the trustee to become a limited partner with Mary as general partner for the continued operation of the business. The partnership interest comprised by far the largest asset in James' estate. The bank entered into a…
1Opinion of the Court
Estate of Mary Z. Bryan, deceased, Byron E. Bryan, Executor v. Commissioner. Estate of James E. Bryan, deceased, First-Citizens Bank and Trust Company, Executor v. Commissioner.
Estate of Bryan v. Commissioner
Docket Nos. 87900, 87901, 90238, 92504.
United States Tax Court
T.C. Memo 1963-182; 1963 Tax Ct. Memo LEXIS 168; 22 T.C.M. (CCH) 864; T.C.M. (RIA) 63182;
June 27, 1963
James and Mary Bryan were equal partners in Bryan Rock and Sand Company, engaged in the quarrying business, prior to James' death in 1953. Under James' will he appointed a bank executor of his estate with directions to pay all…
2Cases cited35 opinions
- Helvering v. TaylorSupreme Court of the United States · 1935
- Freuler v. HelveringSupreme Court of the United States · 1934
- Massey Motors, Inc. v. United StatesSupreme Court of the United States · 1960
- Angelus Milling Co. v. CommissionerSupreme Court of the United States · 1945
- Shomaker v. CommissionerUnited States Tax Court · 1962
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