Vondermuhll v. Commissioner
United States Board of Tax Appeals
Trust funds held by trustees in New York and deposited by them with bankers there produced interest which the bankers paid to the trustees, who paid it to the sole beneficiary, a nonresident alien. Held, the beneficiary is not exempt from income tax thereon under section 217(a)(1)(A) of the Revenue Acts of 1924 and 1926.
1Opinion of the Court
OPINION.
Sea well :
These proceedings, consolidated for hearing, involve re-determination of deficiencies for the respective years 1924, 1925, and 1926 of $3,324.94, $2,868.48, and $4,389.73. Petitioner received certain income as a beneficiary of two trusts during the years 1924, 1925, and 1926, which the respondent determined to be taxable, but which the petitioner claims to be exempt from tax (under section 217, Revenue Act of 1924) on the ground that the income was interest on deposits with persons carrying on the banking business paid to her, a nonresident alien not engaged in business…
2Cases cited5 opinions
- Cornell v. CoyneSupreme Court of the United States · 1904
- Taylor v. Davis' AdministratrixSupreme Court of the United States · 1884
- Swan & Finch Co. v. United StatesSupreme Court of the United States · 1903
- West Wisconsin R. Co. v. Board of Supervisors of Trempealeau Cty.Supreme Court of the United States · 1876
- Richmond v. BlakeSupreme Court of the United States · 1890
3Cited by3 opinions
- Martin-Montis Trust v. CommissionerUnited States Tax Court · 1980
- Martin-Montis Trust v. CommissionerUnited States Tax Court · 1980
- Vondermuhll v. CommissionerUnited States Board of Tax Appeals · 1934