Legal Opinion

Igoe v. Commissioner

United States Tax Court

Decided April 3, 1946No. Docket No. 6580Published

Petitioners, executors of the estate of Andrew J. Igoe, deceased, credited current income on the books of the estate to beneficiaries who were residuary legatees under the decedent's will. The several distributions of income were so credited under circumstances which rendered them constantly available to the beneficiaries on demand. Substantial amounts in cash were withdrawn from the accounts.

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Petitioners, executors of the estate of Andrew J. Igoe, deceased, credited current income on the books of the estate to beneficiaries who were residuary legatees under the decedent's will. The several distributions of income were so credited under circumstances which rendered them constantly available to the beneficiaries on demand. Substantial amounts in cash were withdrawn from the accounts. The method of so treating the distributions was approved by decree of the surrogate settling petitioners' accounts as executors. The beneficiaries reported such distributions on their income tax…

1Opinion of the Court

Estate of Andrew J. Igoe, Peter Igoe and James J. Igoe, Executors, Petitioners, v. Commissioner of Internal Revenue, Respondent

Igoe v. Commissioner

Docket No. 6580

United States Tax Court

6 T.C. 639; 1946 U.S. Tax Ct. LEXIS 244;

April 3, 1946, Promulgated

Decision will be entered under Rule 50.

Petitioners, executors of the estate of Andrew J. Igoe, deceased, credited current income on the books of the estate to beneficiaries who were residuary legatees under the decedent's will. The several distributions of income were so credited under circumstances which rendered them constantly available to the…

2Cases cited3 opinions

  1. Matter of Accounting of BensonNew York Court of Appeals · 1884
  2. Igoe v. CommissionerUnited States Tax Court · 1946
  3. In re the Estate of CochranNew York Surrogate's Court · 1941

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