Kuttroff v. Commissioner
United States Tax Court
1. Awards -- Mixed Claims -- Basis vs. Interest. -- The petitioner received payments during the tax years on an award by the Mixed Claims Commission, United States and Germany. The total amount of the principal award had been received in prior years. Held, the award of interest on the principal award was not a part of the basis and all amounts received in the tax years were interest income.
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1. Awards -- Mixed Claims -- Basis vs. Interest. -- The petitioner received payments during the tax years on an award by the Mixed Claims Commission, United States and Germany. The total amount of the principal award had been received in prior years. Held, the award of interest on the principal award was not a part of the basis and all amounts received in the tax years were interest income. Edna S. Ullman, 34 T.C. 1107, followed. 2. Awards -- Mixed Claims -- Contested Claim-Basis. -- A contested claim settled by a compromise on a dollar amount award does not take a basis larger than the award…
1Opinion of the Court
Estate of Adolf Kuttroff, Deceased, Irving Trust Company, Executor, Petitioner, v. Commissioner of Internal Revenue, Respondent
Kuttroff v. Commissioner
Docket No. 85336
United States Tax Court
38 T.C. 824; 1962 U.S. Tax Ct. LEXIS 82;
September 12, 1962, Filed
Decision will be entered for the respondent.
1. Awards -- Mixed Claims -- Basis vs. Interest. -- The petitioner received payments during the tax years on an award by the Mixed Claims Commission, United States and Germany. The total amount of the principal award had been received in prior years. Held, the award of interest on the principal…
2Cases cited3 opinions
- Ullman v. CommissionerUnited States Tax Court · 1960
- Ullmann v. CommissionerUnited States Board of Tax Appeals · 1934
- Kuttroff v. CommissionerUnited States Tax Court · 1962