Legal Opinion

Brown v. Commissioner

United States Tax Court

Decided December 9, 1942No. Docket Nos. 108948, 108954, 108955PublishedCited by 15 opinions

Interest on gift taxes which were imposed by the Revenue Act of 1924 and determined against the executors of a decedent's estate but paid by beneficiaries of the estate after distribution of the assets of the estate is not an allowable deduction from the income of such beneficiaries.

1Opinion of the Court

opinion.

Turner, Judge:

The respondent determined deficiencies in the income tax against the petitioners for 1939 as follows:

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Issues presented by the pleadings are: (1) whether the petitioners were entitled to deductions of $3,710.56 taken by each of them as interest paid in 1939 on Federal gift taxes for 1924 and 1925 of Paul Brown, who made certain gifts in said years to Julia B. Radford and Nellie B. Keller,, and of whose estate they and Inez H. Brown were beneficiaries ; and (2) whether the petitioners were each entitled to a deduction of $4,622.76 representing the portions of…

2Cited by15 opinions

  1. Federbush v. CommissionerUnited States Tax Court · 1960
  2. Koppers Co. v. CommissionerUnited States Tax Court · 1944
  3. Williams v. CommissionerUnited States Tax Court · 1944
  4. GREEN v. COMMISSIONERUnited States Tax Court · 1944
  5. O'Connor v. CommissionerUnited States Tax Court · 1967

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