Fabens v. Commissioner
United States Tax Court
Upon termination of a trust on June 16, 1969, petitioner paid an annual income commission, an annual principal commission, and paying and receiving commissions to the trustee.
Read the full summary
Upon termination of a trust on June 16, 1969, petitioner paid an annual income commission, an annual principal commission, and paying and receiving commissions to the trustee. The respondent disallowed as a deduction a portion of the annual commission that related to principal in the ratio of tax-exempt ordinary income to total ordinary income realized during the calendar year 1969. In addition, respondent disallowed a portion of the paying and receiving commissions in the ratio of tax-exempt income to total income, including capital gains, realized over the life of the trust. In making his…
1Opinion of the Court
Augustus J. Fabens, Petitioner v. Commissioner of Internal Revenue, Respondent
Fabens v. Commissioner
Docket No. 984-72
United States Tax Court
62 T.C. 775; 1974 U.S. Tax Ct. LEXIS 49; 62 T.C. No. 89;
September 10, 1974, Filed
Decision will be entered under Rule 155.
Upon termination of a trust on June 16, 1969, petitioner paid an annual income commission, an annual principal commission, and paying and receiving commissions to the trustee. The respondent disallowed as a deduction a portion of the annual commission that related to principal in the ratio of tax-exempt ordinary income to total ordinary…
2Cases cited6 opinions
- Willcutts v. BunnSupreme Court of the United States · 1931
- Manufacturers Hanover Trust Company, as Trustee Under Indenture Dated November 15, 1927, Made by Henry H. Rogers, Deceased v. The United StatesUnited States Court of Claims · 1963
- Clinton L. Whittemore, Jr., and Anne W. Whittemore v. United StatesCourt of Appeals for the Eighth Circuit · 1967
- Tucker v. CommissionerUnited States Tax Court · 1962
- Fabens v. CommissionerUnited States Tax Court · 1974
1 more not listed; retrieve them via the Exa API.