Bibby v. Commissioner
United States Tax Court
Income of a trust established by petitioners is taxable to them because the trust failed to satisfy the requirements of section 673(a), I.R.C. 1954.
1Opinion of the Court
Train, Judge:
Respondent determined deficiencies in petitioners’ income taxes as follows:
Year ended— Deficiency
Feb. 28, 1959_$4, 456.73
Feb. 29, 1960_ 3,030.13
Feb. 28, 1961_ 2, 770.36
The basic issue remaining for our decision, after certain concessions embodied in the parties’ stipulation, is whether or not the income reported by a trust established by petitioners is taxable to them because the trust fails to satisfy the requirements of section 671 et seq. of the Internal Revenue Code of 1954.1
FINDINGS OF FACT
Some of the facts have been stipulated, and the stipulation of facts and the exhibits…
2Cases cited5 opinions
- Miller v. CommissionerUnited States Tax Court · 1946
- Stoddard v. EatonDistrict Court, D. Connecticut · 1927
- Garcia v. Garcia De OrtizCourt of Appeals of Texas · 1953
- Reizenstein v. CommissionerUnited States Tax Court · 1954
- Hearn v. CommissionerUnited States Board of Tax Appeals · 1929
3Cited by5 opinions
- Textron Inc. v. Comm'rUnited States Tax Court · 2001
- McGinnis v. CommissionerUnited States Tax Court · 1993
- Bibby v. CommissionerUnited States Tax Court · 1965
- Textron Inc. and Subsidiary Companies v. CommissionerUnited States Tax Court · 2001
- Textron Inc. v. Comm'rUnited States Tax Court · 2001