Willits v. Commissioner
United States Tax Court
1. T was one of several trustees of a trust which terminated in 1960, and which in fact paid $ 920,000 in terminal corpus commissions to the trustees during that year.
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1. T was one of several trustees of a trust which terminated in 1960, and which in fact paid $ 920,000 in terminal corpus commissions to the trustees during that year. By prearrangement with the other trustees, T's share of those commissions was retained by one of the other trustees, a bank, and paid out to him in five annual installments beginning in 1961. Held, T is chargeable with receipt of his entire share of the commissions in 1960. 2. T was also a trustee of four other trusts. As a result of an intermediate accounting in respect thereof, the State court entered a decree in 1961…
1Opinion of the Court
Oliver G. Willits and Margaret F. Willits, Petitioners v. Commissioner of Internal Revenue, Respondent
Willits v. Commissioner
Docket No. 1715-66
United States Tax Court
50 T.C. 602; 1968 U.S. Tax Ct. LEXIS 95;
July 24, 1968, Filed
Decision will be entered under Rule 50.
1. T was one of several trustees of a trust which terminated in 1960, and which in fact paid $ 920,000 in terminal corpus commissions to the trustees during that year. By prearrangement with the other trustees, T's share of those commissions was retained by one of the other trustees, a bank, and paid out to him in five annual…
2Cases cited21 opinions
- Commissioner v. Estate of BoschSupreme Court of the United States · 1967
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
- Harrison v. SchaffnerSupreme Court of the United States · 1941
- H. O. Williams and Mrs. Ada L. Williams v. United StatesCourt of Appeals for the Fifth Circuit · 1955
- Woodbury v. CommissionerUnited States Tax Court · 1967
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