Schick v. Commissioner
United States Board of Tax Appeals
1. INCOME. - Rents and income from property were impounded in the hands of a receiver during litigation to determine the true owner thereof. Held, that the receiver was a fiduciary who should have filed returns and paid the tax on such income.
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1. INCOME. - Rents and income from property were impounded in the hands of a receiver during litigation to determine the true owner thereof. Held, that the receiver was a fiduciary who should have filed returns and paid the tax on such income. Held, further, that when the funds were released and paid over to petitioner in 1922, they were not an item of income to her in that year. 2. DEDUCTION FOR TAXES ON REAL ESTATE. - The petitioner, a life tenant, during the years 1919, 1920, and 1921, paid taxes upon real estate, using borrowed money for that purpose. She repaid the borrowed money in the…
1Opinion of the Court
*1068OPINION.
Tkitssell :
It appears that respondent has included in petitioner’s gross income for 1922 the total amount paid over to her by the Court in that year upon the termination of the litigation and the ascertainment of the party entitled to receive the rents and income from the South Salina Street property. That sum released to petitioner in 1922 included rents and income derived from the property during each of several years while the true ownership of such rents and income was not known and the Court impounded such funds in the hands of a receiver who held them in trust for the…
2Cases cited1 opinion
- United States v. Chicago & E. I. Ry. Co.District Court, N.D. Illinois · 1924
3Cited by9 opinions
- Royal Oak Apartments, Inc. v. CommissionerUnited States Tax Court · 1964
- Eustis v. CommissionerUnited States Board of Tax Appeals · 1934
- Ramos v. CommissionerUnited States Tax Court · 1962
- Sweinhart v. CommissionerUnited States Board of Tax Appeals · 1934
- Clausman v. CommissionerUnited States Tax Court · 1989
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