Bridges v. Commissioner
United States Tax Court
Petitioners received long-term capital gains from a ground lease and timber-cutting contract which was income in respect of a decedent which, after deducting 50 percent thereof under sec. 1202, I.R.C. 1954, exceeded the deduction allowable for estate tax attributable to such income in respect of a decedent allowable under sec. 691(c), I.R.C. 1954. Held, the deduction allowable for estate tax attributable to income in respect of a decedent under sec. 691(c), I.R.C. 1954, in…
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Petitioners received long-term capital gains from a ground lease and timber-cutting contract which was income in respect of a decedent which, after deducting 50 percent thereof under sec. 1202, I.R.C. 1954, exceeded the deduction allowable for estate tax attributable to such income in respect of a decedent allowable under sec. 691(c), I.R.C. 1954. Held, the deduction allowable for estate tax attributable to income in respect of a decedent under sec. 691(c), I.R.C. 1954, in these circumstances need not be offset against the long-term capital gain before allowance of the 50-percent deduction…
1Opinion of the Court
J. T. Bridges, Jr., and Doris E. Bridges, Petitioners v. Commissioner of Internal Revenue, Respondent; Addie Belle Bridges Edwards, Petitioner v. Commissioner of Internal Revenue, Respondent
Bridges v. Commissioner
Docket Nos. 6313-71, 6322-71
United States Tax Court
64 T.C. 968; 1975 U.S. Tax Ct. LEXIS 73;
August 28, 1975, Filed
Decisions will be entered under Rule 155.
Petitioners received long-term capital gains from a ground lease and timber-cutting contract which was income in respect of a decedent which, after deducting 50 percent thereof under sec. 1202, I.R.C. 1954, exceeded the deduction…
2Cases cited15 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Tyler v. United StatesSupreme Court of the United States · 1930
- Walter M. Weil and Adele D. Weil v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1956
- Chartier Real Estate Co. v. CommissionerUnited States Tax Court · 1969
- Chartier Real Estate Company, Inc. v. Commissioner of Internal Revenue, (Three Cases)Court of Appeals for the First Circuit · 1970
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