Sparrow v. Commissioner
United States Board of Tax Appeals
1. Where the will of a decedent directs that the income of the "residuary estate" shall be collected by trustees and the amount in excess of an annual payment made to the widow shall be accumulated for the benefit of minor children and the trustees accumulate and file returns of such excess income, held that the amounts thus accumulated are taxable to the trustees on a single trust. 2. Where one of the minors attained his majority on April 9, 1920, and the Supreme Court of…
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1. Where the will of a decedent directs that the income of the "residuary estate" shall be collected by trustees and the amount in excess of an annual payment made to the widow shall be accumulated for the benefit of minor children and the trustees accumulate and file returns of such excess income, held that the amounts thus accumulated are taxable to the trustees on a single trust. 2. Where one of the minors attained his majority on April 9, 1920, and the Supreme Court of the County of New York, which had jurisdiction in the premises, construed the will to the effect that the provision for…
1Opinion of the Court
*9OPINION.
Smith:
The principle question presented by these proceedings is whether the income of the residuary estate of Edward W. Sparrow, deceased, for the years 1917 to 1920, inclusive, accumulated by the trustees for future distribution in accordance with the terms of the will, should be taxed to the estate as an entity or taxed as the income of three trust estates. Throughout the period the trustees held the estate intact and made a single return each year of such accumulated income and paid the tax shown to be due by such returns.
Section 16 of the Personal Property Law of the State of New…
2Cases cited1 opinion
- Herzog v. . Title Guarantee Trust Co.New York Court of Appeals · 1903
3Cited by20 opinions
- Roebling v. CommissionerUnited States Board of Tax Appeals · 1933
- Spreckels v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1939
- Rauers v. CommissionerUnited States Board of Tax Appeals · 1933
- Umsted v. CommissionerUnited States Board of Tax Appeals · 1933
- Canal Bank & Trust Co. v. CommissionerUnited States Board of Tax Appeals · 1934
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