Legal Opinion

Ullman v. Commissioner

United States Tax Court

Decided September 23, 1960No. Docket No. 76740PublishedCited by 10 opinions

Petitioner, in the taxable years 1954, 1955, and 1956, received payments on an award from the Mixed Claims Commission, United States and Germany. She acquired the right to receive these payments by bequest from her husband who acquired such right by bequest from his mother who in turn had inherited such right from her husband.

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Petitioner, in the taxable years 1954, 1955, and 1956, received payments on an award from the Mixed Claims Commission, United States and Germany. She acquired the right to receive these payments by bequest from her husband who acquired such right by bequest from his mother who in turn had inherited such right from her husband. Petitioner's husband died November 10, 1953. The total amount of the original capital investment of petitioner's father-in-law in the property covered by the award had been received by him prior to his death. Held, the amounts received by petitioner constituted income…

1Opinion of the Court

OPINION.

Scott, Judge:

Respondent determined deficiencies in petitioner’s income tax for the calendar years 1954,1955, and 1956, in the amounts of $281.92, $278.01, and $228.31, respectively. The deficiencies resulted from the inclusion by respondent in petitioner’s income of amounts received by her in the respective years from the Secretary of Treasury of the United States under an award of the Mixed Claims Commission, United States and Germany (hereinafter referred to as the Mixed Claims Commission), made to the Joseph Ullmann Company, a partnership, which amounts respondent determined…

2Cases cited11 opinions

  1. Bailey, Collector of Internal Revenue v. GeorgeSupreme Court of the United States · 1922
  2. Hatch v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1951
  3. Frances E. Latendresse v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1957
  4. Latendresse v. CommissionerUnited States Tax Court · 1956
  5. Commissioner of Internal Revenue v. SpeyerCourt of Appeals for the Second Circuit · 1935

6 more not listed; retrieve them via the Exa API.

3Cited by10 opinions

  1. Agency of Canadian Car & Foundry Co. v. CommissionerUnited States Tax Court · 1962
  2. Graham v. CommissionerUnited States Tax Court · 1961
  3. Estate of Carter v. CommissionerCourt of Appeals for the Eighth Circuit · 1962
  4. Estate Of Mabel G. CarterCourt of Appeals for the Eighth Circuit · 1962
  5. Kuttroff v. CommissionerUnited States Tax Court · 1962

5 more not listed; retrieve them via the Exa API.

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