Copeland v. Commissioner
United States Tax Court
Gross Income -- Bequest -- Annuity -- Payable at Intervals -- Income from Property -- Section 22 (b) (3). -- An annuity payable quarterly and actually paid entirely out of income from property of the testamentary trust is taxable to the beneficiary under section 22 (b) (3), I. R. C.
1Opinion of the Court
OPINION.
Mubdock, Judge'.
The Commissioner determined deficiencies in income tax as follows: 1944, $352.33; 1945, $360.47; and 1946, $303.87.
The only issue is whether $1,500 received by the petitioner in each of the taxable years was properly included in her income under section 22 (b) (3) of the Internal Revenue Code.
The facts have been stipulated.
The petitioner filed her individual income tax returns for the taxable years with the collector of internal revenue for the first district of Pennsylvania.
Joseph V. Horn died, testate, in 1941. His will, with five codicils attached thereto, was duly…
2Cases cited1 opinion
- Townsend v. CommissionerUnited States Tax Court · 1949
3Cited by8 opinions
- Milleg v. CommissionerUnited States Tax Court · 1952
- Williams v. CommissionerUnited States Tax Court · 1961
- Harte v. United StatesDistrict Court, S.D. New York · 1957
- Copeland v. CommissionerUnited States Tax Court · 1949
- Milleg v. CommissionerUnited States Tax Court · 1952
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