Wade v. Commissioner
United States Tax Court
A portion of the current income of a trust for 1940 which the trustee withheld from the life beneficiary and paid over to the executor of the grantor's estate for payment of interest due on an estate tax deficiency determined against the grantor's estate, held, not taxable to the life beneficiary of the trust as income distributable to her.
1Opinion of the Court
OPINION.
Smith, Judge'.
This proceeding is for the redetermination of a deficiency in income tax for the calendar year 1940 in the amount of $21,654.14. Certain of the issues have been settled by stipulations of the parties. The sole remaining issue is whether the respondent has properly included in petitioner’s income, as distributable income of a trust of which she was life beneficiary, a portion of the income of the trust for the taxable year which the trustee transferred to the executor of the grantor’s estate to pay interest on an additional Federal estate tax determined to be due from the…
2Cases cited3 opinions
- Freuler v. HelveringSupreme Court of the United States · 1934
- Pearson v. CommissionerUnited States Tax Court · 1944
- Frye, Trustee v. BurkOhio Court of Appeals · 1936
3Cited by6 opinions
- Anthony v. CommissionerUnited States Tax Court · 1947
- Thornton v. CommissionerUnited States Tax Court · 1945
- Behl v. CommissionerUnited States Tax Court · 1946
- Anthony v. CommissionerUnited States Tax Court · 1947
- Behl v. CommissionerUnited States Tax Court · 1946
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