Cameron v. Commissioner
United States Tax Court
Petitioners received family allowance distributions from their father's estate for the years in issue. The estate had distributable net income in excess of all estate distributions for those years. Petitioners failed to include the distributions in gross income.
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Petitioners received family allowance distributions from their father's estate for the years in issue. The estate had distributable net income in excess of all estate distributions for those years. Petitioners failed to include the distributions in gross income. Held, all family allowance distributions were properly includable in gross income under sec. 662(a), I.R.C. 1954, 2All statutory references are to the Internal Revenue Code of 1954, as amended, unless otherwise stated. whether paid from estate's income or from its corpus. Also held, Commissioner did not abuse his discretion under sec.…
1Opinion of the Court
OPINION
Tietjens, Judge:
The Commissioner determined the following deficiencies in the petitioners’ income taxes:
Petitioner Taxable year Deficiency
Scott D. Cameron. 1967 $8,554.74
1968 14,868.89
Catherine C. Cameron... 1967 5,260.00
1968 2,113.45
Arthur A. Cameron, Jr. 1967 8,802.21
1968 335.00
These cases were fully stipulated pursuant to Rule 122, Tax Court Rules of Practice and Procedure. The facts which we deem necessary for decision will be referred to below. Because each of these cases involves the same issue and is based on the same basic facts, they have been consolidated herein.
The only…
2Cases cited4 opinions
- Estate of WoodwardCalifornia Court of Appeal · 1964
- United States v. Mabel Davis JamesCourt of Appeals for the Ninth Circuit · 1964
- Estate of McCoy v. CommissionerUnited States Tax Court · 1968
- Wiedemann v. WiedemannCalifornia Court of Appeal · 1964
3Cited by4 opinions
- Oakland Hills Country Club v. CommissionerUnited States Tax Court · 1980
- Cameron v. CommissionerUnited States Tax Court · 1977
- Oakland Hills Country Club v. CommissionerUnited States Tax Court · 1980
- Schaefer v. CommissionerUnited States Tax Court · 1983