Legal Opinion

Koepfli v. Commissioner

United States Tax Court

Decided September 23, 1948No. Docket No. 11682Published

1. Held, on the facts, that trust income was to be distributed currently and therefore was taxable to petitioner as beneficiary, under section 162 (b), Internal Revenue Code. 2. Held, that there is no evidence to sustain the respondent's prayer for increased deficiency on the ground that capital losses were charged to corpus and were not deductible from trust income taxable to the petitioner.

1Opinion of the Court

Joseph Blake Koepfli, Petitioner, v. Commissioner of Internal Revenue, Respondent

Koepfli v. Commissioner

Docket No. 11682

United States Tax Court

11 T.C. 352; 1948 U.S. Tax Ct. LEXIS 85;

September 23, 1948, Promulgated

Decision will be entered under Rule 50.

1. Held, on the facts, that trust income was to be distributed currently and therefore was taxable to petitioner as beneficiary, under section 162 (b), Internal Revenue Code.

2. Held, that there is no evidence to sustain the respondent's prayer for increased deficiency on the ground that capital losses were charged to corpus and were not…

2Cases cited2 opinions

  1. Harris v. CommissionerUnited States Tax Court · 1945
  2. Koepfli v. CommissionerUnited States Tax Court · 1948

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