Legal Opinion

Rippey v. Commissioner

United States Tax Court

Decided January 31, 1956No. Docket No. 51720Published

The beneficiary of a testamentary trust agreed to reimburse the executors of the estate if they would pay a stipulated estate tax deficiency. Held, beneficiary's reimbursement payment pursuant to this agreement constituted the payment of Federal estate tax for which she could receive no deduction from her gross income as ordinary and necessary expense under section 23 (a) (2) of the 1939 Code.

1Opinion of the Court

Helen C. Rippey, Petitioner, v. Commissioner of Internal Revenue, Respondent

Rippey v. Commissioner

Docket No. 51720

United States Tax Court

25 T.C. 916; 1956 U.S. Tax Ct. LEXIS 274;

January 31, 1956, Filed

Decision will be entered for the respondent.

The beneficiary of a testamentary trust agreed to reimburse the executors of the estate if they would pay a stipulated estate tax deficiency. Held, beneficiary's reimbursement payment pursuant to this agreement constituted the payment of Federal estate tax for which she could receive no deduction from her gross income as ordinary and necessary expense…

2Cases cited3 opinions

  1. Beck v. CommissionerUnited States Tax Court · 1950
  2. Bache Trust v. CommissionerUnited States Tax Court · 1955
  3. Rippey v. CommissionerUnited States Tax Court · 1956

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