Du Pont Testamentary Trust v. Commissioner
United States Tax Court
Held, expenses incurred by a testamentary trust for maintaining an elaborate estate on which the decedent's widow resided as a "lessee" under an arrangement to pay "rent" of $ 1 a year were not deductible under sec. 212, I.R.C. 1954. Held, further, such expenses were similarly not deductible under sec. 642(c), I.R.C. 1954, merely because the estate was to be transferred to a charitable foundation upon the widow's death.
1Opinion of the Court
Alfred I. duPont Testamentary Trust, The Florida National Bank of Jacksonville, Edward Ball, William B. Mills, J. C. Belin, T. S. Coldewey, W. L. Thornton, and Alfred D. Dent, Trustees, Petitioner v. Commissioner of Internal Revenue, Respondent
Du Pont Testamentary Trust v. Commissioner
Docket No. 330-72
United States Tax Court
62 T.C. 36; 1974 U.S. Tax Ct. LEXIS 124; 62 T.C. No. 6;
April 15, 1974, Filed
Decision will be entered for the respondent.
Held, expenses incurred by a testamentary trust for maintaining an elaborate estate on which the decedent's widow resided as a "lessee" under an…
2Cases cited17 opinions
- Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
- Dixon v. United StatesSupreme Court of the United States · 1965
- Trust Under the Will of Bingham v. CommissionerSupreme Court of the United States · 1945
- International Trading Co. v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1960
- Walet v. CommissionerUnited States Tax Court · 1958
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