Grey v. Commissioner
United States Board of Tax Appeals
1. Amounts paid or permanently set aside to be used exclusively for religious, charitable, etc. purposes are allowed as deductions in computing the income of an estate or trust as provided in subdivision (a) of section 162 of the Revenue Act of 1934 and the organizations receiving such payments may not be classified as beneficiaries for the purpose of applying subdivision (b) of the same section. 2. Dividends, depreciation, tax-exempt income and taxable income should, in the…
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1. Amounts paid or permanently set aside to be used exclusively for religious, charitable, etc. purposes are allowed as deductions in computing the income of an estate or trust as provided in subdivision (a) of section 162 of the Revenue Act of 1934 and the organizations receiving such payments may not be classified as beneficiaries for the purpose of applying subdivision (b) of the same section. 2. Dividends, depreciation, tax-exempt income and taxable income should, in the absence of specific directions in the trust instrument to the contrary, be allocated between the taxable and the…
1Opinion of the Court
*235OPINION.
Mellott:
The Commissioner determined a deficiency in the income tax of petitioners for the year 1934 in the amount of $2,049.05. Inasmuch as all controversies concern the income of Charles F. Grey, he will hereinafter be referred to as the petitioner.
The issue raised in the petition was whether or not the Commissioner erred in disallowing the deduction of $10,331.98 as a bad debt. That issue has now been settled by a stipulation of the parties that the petitioner should be allowed a deduction of $9,056.98.
By an amended answer the respondent asks that the Board “redetermine the correct…
2Cases cited2 opinions
- Edwards v. DouglasSupreme Court of the United States · 1925
- Mason v. RoutzahnSupreme Court of the United States · 1927
3Cited by6 opinions
- Commissioner of Internal Revenue v. Central Hanover Bank & Trust Co.Court of Appeals for the Second Circuit · 1947
- Lambert Tree Trust Estate v. CommissionerUnited States Tax Court · 1962
- Muir v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1950
- Scott v. United StatesUnited States Court of Claims · 1948
- Grey v. CommissionerUnited States Board of Tax Appeals · 1940
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