Legal Opinion

Delp v. Commissioner

United States Tax Court

Decided December 29, 1945No. Docket No. 5719Published

Pursuant to agreements entered into by the petitioner and certain of his brothers and sisters with their brother Charles, involving the income from property left by their mother, Charles became entitled to receive annually 4/24 of the net income from the property for life and the balance was to be equally divided among the other children.

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Pursuant to agreements entered into by the petitioner and certain of his brothers and sisters with their brother Charles, involving the income from property left by their mother, Charles became entitled to receive annually 4/24 of the net income from the property for life and the balance was to be equally divided among the other children. For 1941 petitioner was entitled to receive 5/24 of the net income and another brother and two sisters each a like fraction and Charles 4/24. Each received his pro rata share of the net income from the property for 1941 and reported the same as taxable…

1Opinion of the Court

Frank S. Delp, Petitioner, v. Commissioner of Internal Revenue, Respondent

Delp v. Commissioner

Docket No. 5719

United States Tax Court

5 T.C. 1351; 1945 U.S. Tax Ct. LEXIS 2;

December 29, 1945, Promulgated

Decision will be entered under Rule 50.

Pursuant to agreements entered into by the petitioner and certain of his brothers and sisters with their brother Charles, involving the income from property left by their mother, Charles became entitled to receive annually 4/24 of the net income from the property for life and the balance was to be equally divided among the other children. For 1941…

2Cases cited1 opinion

  1. Delp v. CommissionerUnited States Tax Court · 1945

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