Legal Opinion

Seaboard Nat'l Bank v. Commissioner

United States Board of Tax Appeals

Decided May 15, 1928No. Docket No. 9690Published

1. The petitioner commingled funds of the estate derived from the sale of prior-taxed property with funds derived from other sources, and made expenditures therefrom deductible under paragraph 1 of section 403(a) of the Revenue Act of 1921. The funds from other than prior-taxed property were not sufficient to meet all such expenditures as made, but the present estate at decedent's death, and at all times thereafter, was of sufficient value to cover all charges against it,…

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1. The petitioner commingled funds of the estate derived from the sale of prior-taxed property with funds derived from other sources, and made expenditures therefrom deductible under paragraph 1 of section 403(a) of the Revenue Act of 1921. The funds from other than prior-taxed property were not sufficient to meet all such expenditures as made, but the present estate at decedent's death, and at all times thereafter, was of sufficient value to cover all charges against it, deductible under paragraphs (1) and/or (3) of said section. Held, that the deduction allowable under paragraph 2 of said…

1Opinion of the Court

SEABOARD NATIONAL BANK OF NEW YORK, N.Y., EXECUTOR, ESTATE OF C. FISHER HEPBURN, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Seaboard Nat'l Bank v. Commissioner

Docket No. 9690.

United States Board of Tax Appeals

11 B.T.A. 1386; 1928 BTA LEXIS 3629;

May 15, 1928, Promulgated

1. The petitioner commingled funds of the estate derived from the sale of prior-taxed property with funds derived from other sources, and made expenditures therefrom deductible under paragraph 1 of section 403(a) of the Revenue Act of 1921. The funds from other than prior-taxed property were not sufficient to…

2Cases cited1 opinion

  1. Seaboard Nat'l Bank v. CommissionerUnited States Board of Tax Appeals · 1928

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