Legal Opinion

Bedford v. Commissioner

United States Tax Court

Decided December 22, 1943No. Docket No. 112750Published

Petitioner was an income beneficiary of certain trusts under which the trustee was required to pay the income "as frequently as may be convenient." The corpora of the trusts consisted in part of cumulative preferred stock of corporation A which had been guaranteed by corporation B. Both corporations were reorganized under section 77 (B) of the Federal Bankruptcy Act.

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Petitioner was an income beneficiary of certain trusts under which the trustee was required to pay the income "as frequently as may be convenient." The corpora of the trusts consisted in part of cumulative preferred stock of corporation A which had been guaranteed by corporation B. Both corporations were reorganized under section 77 (B) of the Federal Bankruptcy Act. Under the plan of reorganization the preferred stockholders of corporation A received new preferred stock of that corporation in lieu of the old preferred stock. They also received new preferred stock of corporation B in…

1Opinion of the Court

F. T. Bedford, Petitioner, v. Commissioner of Internal Revenue, Respondent

Bedford v. Commissioner

Docket No. 112750

United States Tax Court

2 T.C. 1189; 1943 U.S. Tax Ct. LEXIS 9;

December 22, 1943, Promulgated

Decision will be entered under Rule 50.

Petitioner was an income beneficiary of certain trusts under which the trustee was required to pay the income "as frequently as may be convenient." The corpora of the trusts consisted in part of cumulative preferred stock of corporation A which had been guaranteed by corporation B. Both corporations were reorganized under section 77 (B) of the Federal…

2Cases cited7 opinions

  1. Blair v. CommissionerSupreme Court of the United States · 1937
  2. Freuler v. HelveringSupreme Court of the United States · 1934
  3. Hort v. CommissionerSupreme Court of the United States · 1941
  4. Groman v. CommissionerSupreme Court of the United States · 1937
  5. Helvering v. BashfordSupreme Court of the United States · 1938

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