Legal Opinion

Neuman v. Commissioner

United States Tax Court

Decided June 30, 1969No. Docket Nos. 6625-66, 6680-66, 6681-66Unpublished

Held, the residuary testamentary trusts created under the wills of Harry and Rose Publicker had not come into existence for Federal tax purposes during the taxable years in question and, accordingly, petitioners' claims regarding the ownership of these trusts, and that the income and deduction items attributable thereto should be treated as their individual items of income and deductions, cannot be sustained.

1Opinion of the Court

Simon S. Neuman and Helen P. Neuman, et al. 1 v. Commissioner.

Neuman v. Commissioner

Docket Nos. 6625-66, 6680-66, 6681-66.

United States Tax Court

T.C. Memo 1969-140; 1969 Tax Ct. Memo LEXIS 164; 28 T.C.M. (CCH) 724; T.C.M. (RIA) 69140;

June 30, 1969, Filed

Held, the residuary testamentary trusts created under the wills of Harry and Rose Publicker had not come into existence for Federal tax purposes during the taxable years in question and, accordingly, petitioners' claims regarding the ownership of these trusts, and that the income and deduction items attributable thereto should be treated as…

2Cases cited9 opinions

  1. Helvering v. CliffordSupreme Court of the United States · 1940
  2. Mallinckrodt v. NunanCourt of Appeals for the Eighth Circuit · 1945
  3. Chick v. CommissionerUnited States Tax Court · 1946
  4. Chick v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1948
  5. Publicker EstateSupreme Court of Pennsylvania · 1956

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