Fossett v. Commissioner
United States Tax Court
Upon the facts, held that the executors properly credited net income for the taxable year to the beneficiaries and are, therefore, entitled to deduct such credits under section 162 (c), Internal Revenue Code, Estate of Andrew J. Igoe, 6 T. C. 639.
1Opinion of the Court
OPINION.
Harron, Judge:
The sole issue is whether the executors properly credited during the taxable year the net income of the estate to the legatees and beneficiaries of the estate within the requirements of section 162 (c), Internal Eevenue Code.2
The respondent admits that the crediting to the beneficiaries occurred within 65 days after the close of the taxable year of the estate and, therefore, falls within the purview of section 162 (d) (8) (A), which provides that amounts paid or credited within 65 days after the close of the taxable year shall be deemed to have been paid or credited upon…
2Cases cited4 opinions
- Commissioner of Internal Revenue v. StearnsCourt of Appeals for the Second Circuit · 1933
- Cohen v. CommissionerUnited States Tax Court · 1947
- Igoe v. CommissionerUnited States Tax Court · 1946
- Zellerbach v. CommissionerUnited States Tax Court · 1947
3Cited by1 opinion
- Fossett v. CommissionerUnited States Tax Court · 1954