Bryant v. Commissioner
United States Tax Court
Petitioner is a secondary income beneficiary and remainderman of a testamentary trust. In the taxable years 1943 and 1944 the trustee received income of the trust which was currently distributable to petitioner.
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Petitioner is a secondary income beneficiary and remainderman of a testamentary trust. In the taxable years 1943 and 1944 the trustee received income of the trust which was currently distributable to petitioner. In 1944 the trustee and petitioner, in lieu of a final judicial accounting, settled the accounts of the trustee, and final distribution was made thereunder on April 3, 1944. Held: (1) The trust existed and the trustee, therefore, continued to be governed by the terms of the trust for a reasonable period following the death of the life beneficiary, and the agreement of settlement of…
1Opinion of the Court
OPINION.
Leech, Judge:
The respondent has determined deficiencies in income and victory tax for the calendar year 1943 in the total of $2,353.31, and a deficiency in income tax for the calendar year 1944 in the sum of $1,221.05. Deficiencies for both of these years arise from respondent’s action in including in petitioner’s income for those years certain dividends received by the trustee of a trust of which the petitioner was a secondary income beneficiary and remainderman.
The proceeding was submitted upon a stipulation of facts, which we find as stipulated.
The petitioner resides in North…
2Cases cited12 opinions
- Freuler v. HelveringSupreme Court of the United States · 1934
- Trust Under the Will of Bingham v. CommissionerSupreme Court of the United States · 1945
- In Re the Accounting of HaleNew York Court of Appeals · 1931
- In Re the Accounting of BeeckmanNew York Court of Appeals · 1930
- In re the Judicial Settlement of the Account of LydonAppellate Division of the Supreme Court of the State of New York · 1923
7 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- Coachman v. CommissionerUnited States Tax Court · 1951
- Rand v. CommissionerUnited States Tax Court · 1959
- Bryant v. CommissionerUnited States Tax Court · 1950
- Estate of Beck v. CommissionerUnited States Tax Court · 1960
- Estate of Bruchmann, etc. v. CommissionerUnited States Tax Court · 1969
2 more not listed; retrieve them via the Exa API.