Widener v. Commissioner
United States Board of Tax Appeals
1. The conduct of racing and breeding stables in the circumstances held a business and the expenses and losses are deductible. 2. Losses and depreciation of trust estate are not pro rata deductions of the distributees of trust income. 3. In determining the taxable net income of beneficiaries under a testamentary trust, the fact that the right, at the time of death, to receive such periodic distributions of income, had a value does not serve to reduce the taxable net income…
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1. The conduct of racing and breeding stables in the circumstances held a business and the expenses and losses are deductible. 2. Losses and depreciation of trust estate are not pro rata deductions of the distributees of trust income. 3. In determining the taxable net income of beneficiaries under a testamentary trust, the fact that the right, at the time of death, to receive such periodic distributions of income, had a value does not serve to reduce the taxable net income embodied in such distributions. Such distributions are income both under the statute and under the Constitution. 4. Such…
1Opinion of the Court
GEORGE D. WIDENER, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
JOSEPH E. WIDENER, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
ELEANOR W. DIXON, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Widener v. Commissioner
Docket Nos. 7723-7727.
United States Board of Tax Appeals
8 B.T.A. 651; 1927 BTA LEXIS 2837;
October 8, 1927, Promulgated
1. The conduct of racing and breeding stables in the circumstances held a business and the expenses and losses are deductible.
2. Losses and depreciation of trust estate are not pro rata deductions of the distributees of…
2Cases cited16 opinions
- Eisner v. MacOmberSupreme Court of the United States · 1920
- Doyle v. Mitchell Brothers Co.Supreme Court of the United States · 1918
- Irwin v. GavitSupreme Court of the United States · 1925
- Simpson v. United StatesSupreme Court of the United States · 1920
- Wilson v. EisnerCourt of Appeals for the Second Circuit · 1922
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