Estate of Bruchmann, etc. v. Commissioner
United States Tax Court
In 1962, after a judicial determination that MB was an income beneficiary of a trust during the period 1949 through 1955, the trustee distributed to MB's estate the income attributable to such period. The trust instrument required the income to be distributed quarterly each year. Held, MB was taxable in 1949 through 1955 on trust income attributable to such period.
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In 1962, after a judicial determination that MB was an income beneficiary of a trust during the period 1949 through 1955, the trustee distributed to MB's estate the income attributable to such period. The trust instrument required the income to be distributed quarterly each year. Held, MB was taxable in 1949 through 1955 on trust income attributable to such period. Held, further, expenses in connection with litigation paid by trustee in 1959 through 1962 do not affect taxability of income withheld from MB in taxable years.
1Opinion of the Court
Tietjens, Judge'.
The respondent determined deficiencies in the income taxes of Mildred Bruchmann as follows:
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We must decide whether she was taxable in the years 1949 through 1955 on certain trust income which was not distributed until 1962, after a judicial determination that she was an income beneficiary of the trust. If we decide that she was, then we must decide whether certain expenses, allocable to the judicial determination and deducted by the trustee from its ultimate distribution, should reduce any trust income found to be includable in Mildred Bruchmann’s gross income…
2Cases cited11 opinions
- United States v. Security Trust & Savings BankSupreme Court of the United States · 1950
- DeBrabant v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1937
- United States v. Francis L. Higginson, TrusteesCourt of Appeals for the First Circuit · 1956
- Gloria M. Packard Polt, Estate of Robert L. Dula, Deceased v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1956
- Bedford v. CommissionerUnited States Tax Court · 1943
6 more not listed; retrieve them via the Exa API.
3Cited by3 opinions
- Estate of Petschek v. CommissionerUnited States Tax Court · 1983
- Estate of Bruchmann, etc. v. CommissionerUnited States Tax Court · 1969
- Estate of Petschek v. CommissionerUnited States Tax Court · 1983