Legal Opinion

Hudson v. Commissioner

United States Tax Court

Decided April 30, 1947No. Docket No. 8695Published

The trustee of a Pennsylvania testamentary trust acquired an office building by deed from the owner, who thereby avoided further payment of ground rent. The trustee paid taxes, repairs, and operating expenses in excess of gross rents in the taxable years, using the trust's gross income, which would otherwise have been payable to the taxpayer, life beneficiary. The Commissioner determined the amounts so used distributable and taxable to the taxpayer beneficiary.

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The trustee of a Pennsylvania testamentary trust acquired an office building by deed from the owner, who thereby avoided further payment of ground rent. The trustee paid taxes, repairs, and operating expenses in excess of gross rents in the taxable years, using the trust's gross income, which would otherwise have been payable to the taxpayer, life beneficiary. The Commissioner determined the amounts so used distributable and taxable to the taxpayer beneficiary. Held: (a) Court approval of the 1937 accounts of a trustee who used income to pay carrying charges on trust-held real estate is…

1Opinion of the Court

Marjorie V. L. Hudson, Petitioner, v. Commissioner of Internal Revenue, Respondent

Hudson v. Commissioner

Docket No. 8695

United States Tax Court

8 T.C. 950; 1947 U.S. Tax Ct. LEXIS 216;

April 30, 1947, Promulgated

Decision will be entered under Rule 50.

The trustee of a Pennsylvania testamentary trust acquired an office building by deed from the owner, who thereby avoided further payment of ground rent. The trustee paid taxes, repairs, and operating expenses in excess of gross rents in the taxable years, using the trust's gross income, which would otherwise have been payable to the taxpayer, life…

2Cases cited16 opinions

  1. Blair v. CommissionerSupreme Court of the United States · 1937
  2. Freuler v. HelveringSupreme Court of the United States · 1934
  3. Nirdlinger's Estate (No. 2)Supreme Court of Pennsylvania · 1937
  4. Nirdlinger's EstateSupreme Court of Pennsylvania · 1938
  5. Levy's EstateSupreme Court of Pennsylvania · 1939

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