Bridges v. Commissioner
United States Tax Court
Petitioners received long-term capital gains from a ground lease and timber-cutting contract which was income in respect of a decedent which, after deducting 50 percent thereof under sec. 1202, I.R.C. 1954, exceeded the deduction allowable for estate tax attributable to such income in respect of a decedent allowable under sec. 691(c), I.R.C. 1954. Held, the deduction allowable for estate tax attributable to income in respect of a decedent under sec. 691(c), I.R.C. 1954, in…
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Petitioners received long-term capital gains from a ground lease and timber-cutting contract which was income in respect of a decedent which, after deducting 50 percent thereof under sec. 1202, I.R.C. 1954, exceeded the deduction allowable for estate tax attributable to such income in respect of a decedent allowable under sec. 691(c), I.R.C. 1954. Held, the deduction allowable for estate tax attributable to income in respect of a decedent under sec. 691(c), I.R.C. 1954, in these circumstances need not be offset against the long-term capital gain before allowance of the 50-percent deduction…
1Opinion of the Court
Goffe, Judge:
The Commissioner determined deficiencies in petitioners’ Federal income tax as follows:
Petitioner Taxable year Deficiency
J. T. Bridges, Jr., and Doris E. Bridges_ 1963 $2,177.00
1964 1,631.81
1963 22,392.90 Addie Belle Bridges Edwards
1964 6,936.67
These cases were consolidated for trial, briefs, and opinion. The sole issue for decision is whether the deduction allowable for estate tax attributable to income in respect of a decedent (sec. 691(c))1 which is long-term capital gain must be offset against the long-term capital gain or is allowable as an itemized deduction where the…
2Cases cited14 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Tyler v. United StatesSupreme Court of the United States · 1930
- Walter M. Weil and Adele D. Weil v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1956
- Chartier Real Estate Co. v. CommissionerUnited States Tax Court · 1969
- Chartier Real Estate Company, Inc. v. Commissioner of Internal Revenue, (Three Cases)Court of Appeals for the First Circuit · 1970
9 more not listed; retrieve them via the Exa API.
3Cited by9 opinions
- B. C. Cook & Sons, Inc. v. CommissionerUnited States Tax Court · 1975
- Estate of Sidles v. CommissionerUnited States Tax Court · 1976
- Estate of Graves v. CommissionerUnited States Tax Court · 1989
- B. C. Cook & Sons, Inc. v. CommissionerUnited States Tax Court · 1975
- Bridges v. CommissionerUnited States Tax Court · 1975
4 more not listed; retrieve them via the Exa API.