Warburton v. Commissioner
United States Tax Court
Petitioners are life beneficiaries under a trust which, in 1947, sold $ 1,500,000 face amount of bonds for $ 660,000, thereby sustaining a capital loss. Under Pennsylvania statutes a portion of the sales proceeds was allocated to the income beneficiaries. Neither Mary B. Warburton, deceased, nor Thomas B. Wanamaker, Jr., made any reference on their 1947 Federal income tax returns to the sale of the bonds made by the trust in that year.
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Petitioners are life beneficiaries under a trust which, in 1947, sold $ 1,500,000 face amount of bonds for $ 660,000, thereby sustaining a capital loss. Under Pennsylvania statutes a portion of the sales proceeds was allocated to the income beneficiaries. Neither Mary B. Warburton, deceased, nor Thomas B. Wanamaker, Jr., made any reference on their 1947 Federal income tax returns to the sale of the bonds made by the trust in that year. No portion of the amount so allocated was reported on their 1948 returns either by the decedent or by Thomas B. Wanamaker, Jr. However, a statement was…
1Opinion of the Court
OPINION.
Muleoney, Judge:
Respondent determined deficiencies for the year 1947 in the Federal income tax of the Estate of Mary B. Warburton in the amount of $110,744.77 and in the Federal income tax of Thomas B. Wanamaker, Jr., in the amount of $42,268.12. The issues are (1) whether certain distributions by a trust on March ll, 1948, constituted ordinary income to the beneficiary-recipients; and (2) whether sections 1311-1315 of the 1954 Internal Revenue Code are applicable to the facts of this controversy.
It is stipulated that the records in Docket Nos. 44289 and 44290, the prior cases before…
2Cases cited7 opinions
- Burnet v. WhitehouseSupreme Court of the United States · 1931
- Plunkett v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1941
- Brennen v. CommissionerUnited States Tax Court · 1953
- Johnston v. HelveringCourt of Appeals for the Second Circuit · 1944
- Cory v. CommissionerUnited States Tax Court · 1958
2 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- Kent Homes, Inc. v. CommissionerUnited States Tax Court · 1971
- Bradford v. CommissionerUnited States Tax Court · 1960
- Burgwin v. CommissionerUnited States Tax Court · 1959
- Bradford v. CommissionerUnited States Tax Court · 1960
- Burgwin v. CommissionerUnited States Tax Court · 1959
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