Legal Opinion

Hormel v. Commissioner

United States Board of Tax Appeals

Decided February 29, 1932No. Docket Nos. 34765-34767, 44967-44969, 55631, 55632Published

1. The evidence is insufficient to establish what portion, if any, of the income received by certain beneficiaries of a trust represents taxes thereon. 2. In the circumstances herein amounts received by the petitioners taxes thereon. as beneficiaries of a trust can not be identified as dividends received from domestic corporations for the purpose of allowing credit in computing income subject to normal tax.

1Opinion of the Court

JOHN G. HORMEL, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

BENJAMIN F. HORMEL, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

O. W. O'BERG, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Hormel v. Commissioner

Docket Nos. 34765-34767, 44967-44969, 55631, 55632.

United States Board of Tax Appeals

25 B.T.A. 703; 1932 BTA LEXIS 1485;

February 29, 1932, Promulgated

1. The evidence is insufficient to establish what portion, if any, of the income received by certain beneficiaries of a trust represents taxes thereon.

2. In the circumstances herein amounts…

2Cases cited1 opinion

  1. Hormel v. CommissionerUnited States Board of Tax Appeals · 1932

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