Fry v. Commissioner
United States Tax Court
Petitioners were remaindermen of a trust whose corpus consisted of corporate stock. They purchased the life income interests of the other beneficiaries of the trust, whereupon the stock was distributed to them. Held, the amounts paid for the life income interests in the trust were properly amortizable ratably over the terms of the life interests. Bell v. Harrison, (C. A. 7) 212 F. 2d 253, followed.
1Opinion of the Court
OPINION.
Tietjens, Judge:
The Commissioner determined the following deficiencies in income tax:
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The sole question for decision is whether petitioners, the sole re-maindermen of a trust estate consisting of stock in a corporation, who purchased intervening life interests in the estate are entitled to recover their cost through amortization over the terms of the life interests.
All of the facts are stipulated and the stipulation of facts together with the pertinent exhibits are included herein by this reference.
The pertinent facts may be summarized as follows:
Petitioners William N.…
2Cases cited4 opinions
- Bell v. Harrison. Bell v. United StatesCourt of Appeals for the Seventh Circuit · 1954
- Risko v. CommissionerUnited States Tax Court · 1956
- Heller Trust v. CommissionerUnited States Tax Court · 1946
- Wells Fargo Bank & Union Trust Co. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1947
3Cited by19 opinions
- Early v. CommissionerUnited States Tax Court · 1969
- Triangle Publications, Inc. v. CommissionerUnited States Tax Court · 1970
- Allen M. Early and Jeannette B. Early v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1971
- Spruance v. CommissionerUnited States Tax Court · 1973
- Manufacturers Hanover Trust Co. v. CommissionerCourt of Appeals for the Second Circuit · 1970
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