Early v. Commissioner
United States Tax Court
Petitioners acquired a joint life interest in a percentage of the income from an estate trust in exchange for their transfer to the trust of certain shares of stock transferred to them by decedent outside her probate estate. Held, the amortized cost of acquiring the life estate is deductible under sec. 167(a)(2), I.R.C. 1954. Held, further, that portion of the amortized cost allocable to tax-exempt interest income is not disallowed as a deduction by sec. 265, I.R.C. 1954.
1Opinion of the Court
Allen M. Early and Jeannette B. Early, Petitioners v. Commissioner of Internal Revenue, Respondent
Early v. Commissioner
Docket No. 802-67
United States Tax Court
52 T.C. 560; 1969 U.S. Tax Ct. LEXIS 102;
June 26, 1969, Filed
Decision will be entered under Rule 50.
Petitioners acquired a joint life interest in a percentage of the income from an estate trust in exchange for their transfer to the trust of certain shares of stock transferred to them by decedent outside her probate estate. Held, the amortized cost of acquiring the life estate is deductible under sec. 167(a)(2), I.R.C. 1954. Held,…
Also in this document: Dissent · Withey; Dissent · Scott; Dissent · Tannenwald.
2Cases cited39 opinions
- Crane v. CommissionerSupreme Court of the United States · 1947
- Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
- Lyeth v. HoeySupreme Court of the United States · 1938
- Trust Under the Will of Bingham v. CommissionerSupreme Court of the United States · 1945
- Helvering v. OwensSupreme Court of the United States · 1939
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