Coachman v. Commissioner
United States Tax Court
Deductions -- Losses -- Whose -- Trust or Remaindermen. -- Losses from the sales of securities made by a trustee in order to distribute the corpus of a trust to fifty remaindermen after the death of the life beneficiary are not losses of the remaindermen for Federal income tax purposes.
1Opinion of the Court
OPINION.
Mukdock, Judge:
The Commissioner determined a deficiency of $816.29 in income tax for 1945. One issue for decision is whether the petitioner or a trust is entitled to the benefit of a long term capital loss on the sale of securities and, if the petitioner is entitled to the benefit, the amount of her basis for computing the loss is in controversy. The facts essential to the first issue have been stipulated.
Joseph A. Williams transferred bonds in trust to Marine Trust Company of Buffalo, New York, in 1929. The trust was to be governed by the laws of New York. The trustee was to pay the…
2Cases cited9 opinions
- Trust Under the Will of Bingham v. CommissionerSupreme Court of the United States · 1945
- In Re the Accounting of HaleNew York Court of Appeals · 1931
- In Re the Accounting of BeeckmanNew York Court of Appeals · 1930
- In Re the Will of McManusNew York Court of Appeals · 1940
- Bryant v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1950
4 more not listed; retrieve them via the Exa API.
3Cited by6 opinions
- Neave v. CommissionerUnited States Tax Court · 1952
- Gustave T. Swoboda and Emily L. Swoboda, Husband and Wife v. United StatesCourt of Appeals for the Third Circuit · 1958
- Agnew v. CommissionerUnited States Tax Court · 1951
- Coachman v. CommissionerUnited States Tax Court · 1951
- Jones v. CommissionerUnited States Tax Court · 1954
1 more not listed; retrieve them via the Exa API.