Legal Opinion

Sneed v. Commissioner

United States Tax Court

Decided June 23, 1953No. Docket No. 27716UnpublishedCited by 1 opinion

1. Petitioner was an annuitant beneficiary of her deceased husband's estate in the amount of $15,000 per annum, the residue of the income of the estate being distributable to the deceased's daughter. A Texas court of competent jurisdiction has held that the said $15,000 payable to petitioner was payable only out of income of the estate. Held, that the annuity payments to petitioner were income taxable to her.

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1. Petitioner was an annuitant beneficiary of her deceased husband's estate in the amount of $15,000 per annum, the residue of the income of the estate being distributable to the deceased's daughter. A Texas court of competent jurisdiction has held that the said $15,000 payable to petitioner was payable only out of income of the estate. Held, that the annuity payments to petitioner were income taxable to her. Rationale of Estate of J. T. Sneed, Jr., 17 T.C. 1344, followed. 2. Part of the income of the estate during each of the taxable years 1942 and 1943 was from depletable property belonging…

1Opinion of the Court

Brad Love Sneed v. Commissioner.

Sneed v. Commissioner

Docket No. 27716.

United States Tax Court

1953 Tax Ct. Memo LEXIS 199; 12 T.C.M. (CCH) 711; T.C.M. (RIA) 53223;

June 23, 1953

1. Petitioner was an annuitant beneficiary of her deceased husband's estate in the amount of $15,000 per annum, the residue of the income of the estate being distributable to the deceased's daughter. A Texas court of competent jurisdiction has held that the said $15,000 payable to petitioner was payable only out of income of the estate. Held, that the annuity payments to petitioner were income taxable to her. Rationale…

2Cases cited8 opinions

  1. Helvering v. ButterworthSupreme Court of the United States · 1933
  2. Burnet v. WhitehouseSupreme Court of the United States · 1931
  3. Sneed v. CommissionerUnited States Tax Court · 1952
  4. Sneed v. PoolCourt of Appeals of Texas · 1950
  5. Fleming v. CommissionerUnited States Board of Tax Appeals · 1941

3 more not listed; retrieve them via the Exa API.

3Cited by1 opinion

  1. Robinett v. CommissionerUnited States Tax Court · 1962

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