Dula v. Commissioner
United States Tax Court
Sec. 162 (b), I. R. C. 1939 -- Income Currently Distributable -- Year of Taxability -- Estoppel. -- Decedent was the life income beneficiary of a trust, part of the corpus of which consisted of interests in bonds and mortgages on two pieces of real property. The trustee foreclosed the mortgages and in 1944 and 1945 sold the properties after having engaged in mortgage-salvage operations for a number of years.
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Sec. 162 (b), I. R. C. 1939 -- Income Currently Distributable -- Year of Taxability -- Estoppel. -- Decedent was the life income beneficiary of a trust, part of the corpus of which consisted of interests in bonds and mortgages on two pieces of real property. The trustee foreclosed the mortgages and in 1944 and 1945 sold the properties after having engaged in mortgage-salvage operations for a number of years. The consideration for the sale consisted partly of cash and partly of purchase money bonds and mortgages. The trustee allocated to decedent in May of 1945 a certain portion of the sales…
1Opinion of the Court
Estate of Robert L. Dula, Deceased, Gloria M. Packard Polt, Executrix, Petitioner, v. Commissioner of Internal Revenue, Respondent
Dula v. Commissioner
Docket No. 43662
United States Tax Court
23 T.C. 646; 1955 U.S. Tax Ct. LEXIS 269;
January 18, 1955, Filed
Decision will be entered under Rule 50.
Sec. 162 (b), I. R. C. 1939 -- Income Currently Distributable -- Year of Taxability -- Estoppel. -- Decedent was the life income beneficiary of a trust, part of the corpus of which consisted of interests in bonds and mortgages on two pieces of real property. The trustee foreclosed the mortgages and in 1944…
2Cases cited8 opinions
- Plunkett v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1941
- In Re the Will of ChapalNew York Court of Appeals · 1936
- In Re the Accounting of Bankers Trust Company, as Trustee Under the Will of OtisNew York Court of Appeals · 1937
- Johnston v. HelveringCourt of Appeals for the Second Circuit · 1944
- DeBrabant v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1937
3 more not listed; retrieve them via the Exa API.