Dauphin Deposit Trust Co. v. Commissioner
United States Board of Tax Appeals
A trust is not taxable as an association where it was organized for the purpose of managing property pending advantageous disposition and distribution of the proceeds to the beneficiaries and where the business activities carried on were merely incidental to the main purpose of distribution.
1Opinion of the Court
DAUPHIN DEPOSIT TRUST CO., TRUSTEE OF ESTATE OF JAMES MCCORMICK, DECEASED, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Dauphin Deposit Trust Co. v. Commissioner
Docket No. 41387.
United States Board of Tax Appeals
21 B.T.A. 1214; 1931 BTA LEXIS 2231;
January 16, 1931, Promulgated
A trust is not taxable as an association where it was organized for the purpose of managing property pending advantageous disposition and distribution of the proceeds to the beneficiaries and where the business activities carried on were merely incidental to the main purpose of distribution.
Ralph J. Baker,…
2Cases cited7 opinions
- Hecht v. MalleySupreme Court of the United States · 1924
- Von Baumbach v. Sargent Land Co.Supreme Court of the United States · 1917
- E. A. Landreth Co. v. CommissionerUnited States Board of Tax Appeals · 1928
- Dauphin Deposit Trust Co. v. CommissionerUnited States Board of Tax Appeals · 1931
- Wilson Trust v. CommissionerUnited States Board of Tax Appeals · 1930
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