Legal Opinion

Commercial Trust Co. v. Commissioner

United States Board of Tax Appeals

Decided February 19, 1930No. Docket Nos. 31926, 31927Published

The petitioner was created by a declaration of trust made November 1, 1920. Property of the value of $100,000 was transferred to a sole trustee. Power to terminate the trust was reserved to the beneficiaries. The petitioner was actively engaged in carrying on a business during the years 1922, 1923, and 1924 and filed fiduciary returns for those years.

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The petitioner was created by a declaration of trust made November 1, 1920. Property of the value of $100,000 was transferred to a sole trustee. Power to terminate the trust was reserved to the beneficiaries. The petitioner was actively engaged in carrying on a business during the years 1922, 1923, and 1924 and filed fiduciary returns for those years. The Lone Star Realty Co. was created by a similar declaration of trust made January 20, 1922. Property of the value of $25,000 was transferred to a sole trustee. The trust carried on an active business during the years 1922 and 1923 and filed…

1Opinion of the Court

COMMERCIAL TRUST CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Commercial Trust Co. v. Commissioner

Docket Nos. 31926, 31927.

United States Board of Tax Appeals

18 B.T.A. 1248; 1930 BTA LEXIS 2494;

February 19, 1930, Promulgated

The petitioner was created by a declaration of trust made November 1, 1920. Property of the value of $100,000 was transferred to a sole trustee. Power to terminate the trust was reserved to the beneficiaries. The petitioner was actively engaged in carrying on a business during the years 1922, 1923, and 1924 and filed fiduciary returns for those years.…

2Cases cited9 opinions

  1. Hecht v. MalleySupreme Court of the United States · 1924
  2. Burk-Waggoner Oil Assn. v. HopkinsSupreme Court of the United States · 1925
  3. Crocker v. MalleySupreme Court of the United States · 1919
  4. E. A. Landreth Co. v. CommissionerUnited States Board of Tax Appeals · 1929
  5. E. A. Landreth Co. v. CommissionerUnited States Board of Tax Appeals · 1928

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