Fifth Third Union Trust Co. v. Commissioner
United States Board of Tax Appeals
1. Where respondent determines a tax on the income received by a trustee under a will from property coming into such trustee's hands under the will, but sends a deficiency notice to the executor, who was a different person from the trustee, and the trustee files with the Board a petition from such notice, the proceeding will be dismissed for lack of jurisdiction. 2. Held that the trusts here involved are not exempt from taxation under the provisions of section 231(6) of the…
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1. Where respondent determines a tax on the income received by a trustee under a will from property coming into such trustee's hands under the will, but sends a deficiency notice to the executor, who was a different person from the trustee, and the trustee files with the Board a petition from such notice, the proceeding will be dismissed for lack of jurisdiction. 2. Held that the trusts here involved are not exempt from taxation under the provisions of section 231(6) of the Revenue Act of 1921. 3. Held that the petitioners are not entitled to the deductions taken in their returns for income…
1Opinion of the Court
FIFTH THIRD UNION TRUST CO., TRUSTEE UNDER THE WILL OF JACOB G. SCHMIDLAPP, DECEASED, TRUST FUND NO. 1340, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
FIFTH THIRD UNION TRUST CO., TRUSTEE OF THE CHARLOTTE R. SCHMIDLAPP FUND, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
FIFTH THIRD UNION TRUST CO., TRUSTEE OF A TRUST FUND UNDER DEED OF TRUST OF JACOB G. SCHMIDLAPP, DESIGNATED FUND NO. 1163, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
EDGAR STARK, EXECUTOR, ESTATE OF JACOB G. SCHMIDLAPP, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
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2Cases cited1 opinion
- Fifth Third Union Trust Co. v. CommissionerUnited States Board of Tax Appeals · 1930