Hudson v. Commissioner
United States Tax Court
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.
Read the full summary
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
- Blair v. CommissionerSupreme Court of the United States · 1937
- Freuler v. HelveringSupreme Court of the United States · 1934
- Nirdlinger's Estate (No. 2)Supreme Court of Pennsylvania · 1937
- Nirdlinger's EstateSupreme Court of Pennsylvania · 1938
- Levy's EstateSupreme Court of Pennsylvania · 1939
11 more not listed; retrieve them via the Exa API.