Union Trust Co. v. Commissioner
United States Board of Tax Appeals
INCOME TAXABLE TO FIDUCIARY WHERE DISTRIBUTIONS MADE OUT OF CORPUS AND INCOME. - Nieces of a testatrix were given substantial rights under a will. They agreed to accept, in lieu of the gifts made to them by the will, annuities of $5,000 each, payable out of the income of a trust if sufficient for that purpose, but if not, then out of corpus of the trust estate. During taxable year one-fourth of total paid to them was from corpus.
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INCOME TAXABLE TO FIDUCIARY WHERE DISTRIBUTIONS MADE OUT OF CORPUS AND INCOME. - Nieces of a testatrix were given substantial rights under a will. They agreed to accept, in lieu of the gifts made to them by the will, annuities of $5,000 each, payable out of the income of a trust if sufficient for that purpose, but if not, then out of corpus of the trust estate. During taxable year one-fourth of total paid to them was from corpus. Held, the income of the trust estate was taxable to the fiduciary and the distributions made by it were not deductible under section 162(b) of the Revenue Act of…
1Opinion of the Court
THE UNION TRUST CO. OF PITTSBURGH, TRUSTEE ESTATE OF ANNIE M. WALLACE, DECEASED, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Union Trust Co. v. Commissioner
Docket No. 78914.
United States Board of Tax Appeals
34 B.T.A. 284; 1936 BTA LEXIS 718;
April 8, 1936, Promulgated
INCOME TAXABLE TO FIDUCIARY WHERE DISTRIBUTIONS MADE OUT OF CORPUS AND INCOME. - Nieces of a testatrix were given substantial rights under a will. They agreed to accept, in lieu of the gifts made to them by the will, annuities of $5,000 each, payable out of the income of a trust if sufficient for that purpose, but…
2Cases cited10 opinions
- Helvering v. ButterworthSupreme Court of the United States · 1933
- Burnet v. WhitehouseSupreme Court of the United States · 1931
- Barber v. WestcottSupreme Court of Rhode Island · 1899
- Boston Safe Deposit & Trust Co. v. CommissionerUnited States Board of Tax Appeals · 1932
- McClung v. CommissionerUnited States Board of Tax Appeals · 1928
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