Coursey v. Commissioner
United States Board of Tax Appeals
1. One half the profit from a sale of land by a trust from which the grantor could withdraw at discretion for her needs amounts not to exceed half the net value of the corpus, held, taxable to the grantor.
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1. One half the profit from a sale of land by a trust from which the grantor could withdraw at discretion for her needs amounts not to exceed half the net value of the corpus, held, taxable to the grantor. Sec. 166, Revenue Act of 1928. 2. The words "title" and "part of the corpus", as used in section 166, Revenue Act of 1928, do not imply an identification of specific property. 3. A trust instrument, reserving to the settlor a power of appointment by will, which had not been exercised, held, to create an adverse present interest in those who would under Maryland law take by intestate…
1Opinion of the Court
SARAH A. W. COURSEY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Coursey v. Commissioner
Docket No. 71755.
United States Board of Tax Appeals
33 B.T.A. 1068; 1936 BTA LEXIS 788;
February 11, 1936, Promulgated
1. One half the profit from a sale of land by a trust from which the grantor could withdraw at discretion for her needs amounts not to exceed half the net value of the corpus, held, taxable to the grantor. Sec. 166, Revenue Act of 1928.
2. The words "title" and "part of the corpus", as used in section 166, Revenue Act of 1928, do not imply an identification of specific property.
2Cases cited1 opinion
- Coursey v. CommissionerUnited States Board of Tax Appeals · 1936