Legal Opinion

Simon v. Commissioner

United States Board of Tax Appeals

Decided March 6, 1928No. Docket No. 9993Published

Deductions by trustees from interest received on bonds purchased with trust funds are not income to taxpayer beneficiary, inasmuch as under the laws of the State of New York, the trustees were required to create a sinking fund out of interest paid to them on bonds, sufficient to make good upon their maturity the premium paid therefor, to the end that the principal of the trust fund might be preserved intact.

1Opinion of the Court

KATE M. SIMON, BY HER AGENT, ALEXANDER B. SIMON, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Simon v. Commissioner

Docket No. 9993.

United States Board of Tax Appeals

10 B.T.A. 1186; 1928 BTA LEXIS 3942;

March 6, 1928, Promulgated

Deductions by trustees from interest received on bonds purchased with trust funds are not income to taxpayer beneficiary, inasmuch as under the laws of the State of New York, the trustees were required to create a sinking fund out of interest paid to them on bonds, sufficient to make good upon their maturity the premium paid therefor, to the end that the…

2Cases cited1 opinion

  1. Simon v. CommissionerUnited States Board of Tax Appeals · 1928

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