Bull v. Commissioner
United States Board of Tax Appeals
1. Estate tax accrues at time of death and not when payable. 2. The word "accrue" has no definite meaning but must be interpreted in accordance with the statutory requirement that the accounts must clearly reflect income. 3. Estate tax and income tax are different in kind and incidence and are not mutually exclusive because imposed in respect of the same matter. Such double tax is not invalid.
1Opinion of the Court
ERNEST M. BULL, EXECUTOR, ESTATE OF ARCHIBARD H. BULL, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Bull v. Commissioner
Docket No. 6888.
United States Board of Tax Appeals
7 B.T.A. 993; 1927 BTA LEXIS 3038;
August 8, 1927, Promulgated
1. Estate tax accrues at time of death and not when payable.
2. The word "accrue" has no definite meaning but must be interpreted in accordance with the statutory requirement that the accounts must clearly reflect income.
3. Estate tax and income tax are different in kind and incidence and are not mutually exclusive because imposed in respect of the…
2Cases cited22 opinions
- United States v. AndersonSupreme Court of the United States · 1926
- Knowlton v. MooreSupreme Court of the United States · 1900
- New York Trust Co. v. EisnerSupreme Court of the United States · 1921
- Irwin v. GavitSupreme Court of the United States · 1925
- New Jersey v. AndersonSupreme Court of the United States · 1906
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