Davis v. Commissioner
United States Tax Court
1. During its taxable year 1942, H. S. D. Co. established a profit sharing plan for its executive employees and its hourly-paid employees and as part of the plan established a separate trust for each of those groups of its employees. During 1948 Harold S. Davis, a participant in the trust for the executive employees, died and thereafter during that year the trustee of that trust distributed in one sum to petitioner, Mary Davis, his interest in the trust.
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1. During its taxable year 1942, H. S. D. Co. established a profit sharing plan for its executive employees and its hourly-paid employees and as part of the plan established a separate trust for each of those groups of its employees. During 1948 Harold S. Davis, a participant in the trust for the executive employees, died and thereafter during that year the trustee of that trust distributed in one sum to petitioner, Mary Davis, his interest in the trust. She reported said sum as taxable as gain from the sale or exchange of a capital asset held for more than 6 months. Respondent determined…
1Opinion of the Court
Estate of Harold S. Davis, Deceased, Mary Davis, Executrix, and Mary Davis, Surviving Wife, Petitioners, v. Commissioner of Internal Revenue, Respondent
Davis v. Commissioner
Docket No. 40005
United States Tax Court
22 T.C. 807; 1954 U.S. Tax Ct. LEXIS 158;
June 30, 1954, Filed June 30, 1954, Filed
Decision will be entered under Rule 50.
1. During its taxable year 1942, H. S. D. Co. established a profit sharing plan for its executive employees and its hourly-paid employees and as part of the plan established a separate trust for each of those groups of its employees. During 1948 Harold S. Davis, a…
2Cases cited7 opinions
- Commissioner v. SunnenSupreme Court of the United States · 1948
- H. S. D. Co. v. Kavanagh, Collector of Internal RevenueCourt of Appeals for the Sixth Circuit · 1951
- Lincoln Electric Co. Employees' Profit-Sharing Trust v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1951
- Lincoln Electric Co. Employees' Profit-Sharing Trust v. CommissionerUnited States Tax Court · 1950
- H. S. D. Co. v. KavanaghDistrict Court, E.D. Michigan · 1950
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