Lonergan v. Commissioner
United States Tax Court
1. A decree of the Missouri Circuit Court, entered in a proceeding to construe decedent's will, directed the trustees of the testamentary trust created by the will to first satisfy a judgment against decedent's estate by the payment of $ 300 monthly thereon out of the income of the trust estate.
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1. A decree of the Missouri Circuit Court, entered in a proceeding to construe decedent's will, directed the trustees of the testamentary trust created by the will to first satisfy a judgment against decedent's estate by the payment of $ 300 monthly thereon out of the income of the trust estate. Held, the payments on this judgment did not constitute distributions to a beneficiary, as such, but were payments on account of a debt of the decedent and consequently were not deductible in computing the net taxable income of the trust estate under section 162 (b), I. R. C. 2. Section 23 (c) (1) (A),…
1Opinion of the Court
Trust Estate of Thomas Lonergan, Robert L. Jackson, C. P. LeMire and T. H. Mastin, Trustees, Petitioners, v. Commissioner of Internal Revenue, Respondent
Lonergan v. Commissioner
Docket No. 7844
United States Tax Court
6 T.C. 715; 1946 U.S. Tax Ct. LEXIS 234;
April 12, 1946, Promulgated
Decision will be entered under Rule 50.
1. A decree of the Missouri Circuit Court, entered in a proceeding to construe decedent's will, directed the trustees of the testamentary trust created by the will to first satisfy a judgment against decedent's estate by the payment of $ 300 monthly thereon out of the income of…
2Cases cited3 opinions
- Freuler v. HelveringSupreme Court of the United States · 1934
- Trust Under the Will of Bingham v. CommissionerSupreme Court of the United States · 1945
- Lonergan v. CommissionerUnited States Tax Court · 1946