Astor v. Commissioner
United States Board of Tax Appeals
1. Property, held in a trust of which the petitioner was a life beneficiary, was condemned and taken by the city of New York prior to the taxable year. The city paid to the trust in the taxable year as just compensation an amount representing the value of the property taken, with interest thereon from the date of the taking. The amount computed as interest was distributable to the petitioner in the taxable year.
Read the full summary
1. Property, held in a trust of which the petitioner was a life beneficiary, was condemned and taken by the city of New York prior to the taxable year. The city paid to the trust in the taxable year as just compensation an amount representing the value of the property taken, with interest thereon from the date of the taking. The amount computed as interest was distributable to the petitioner in the taxable year. Held, that if the amount was interest, it represented interest on obligations of a resident within the meaning of section 119(a)(1) of the Revenue Act of 1928 and was taxable to the…
1Opinion of the Court
WALDORF ASTOR, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Astor v. Commissioner
Docket No. 64269.
United States Board of Tax Appeals
31 B.T.A. 1009; 1935 BTA LEXIS 1036;
January 9, 1935, Promulgated
1. Property, held in a trust of which the petitioner was a life beneficiary, was condemned and taken by the city of New York prior to the taxable year. The city paid to the trust in the taxable year as just compensation an amount representing the value of the property taken, with interest thereon from the date of the taking. The amount computed as interest was distributable to the…
2Cases cited5 opinions
- Helvering v. Stockholms Enskilda BankSupreme Court of the United States · 1934
- British-American Tobacco Co. v. HelveringSupreme Court of the United States · 1934
- Bandes v. CommissionerUnited States Board of Tax Appeals · 1933
- Isham v. CommissionerUnited States Board of Tax Appeals · 1932
- Astor v. CommissionerUnited States Board of Tax Appeals · 1935