Igoe v. Commissioner
United States Tax Court
Estate Income Properly Credited to Beneficiaries -- Sec. 162 (c), I. R. C. -- Under the facts, held that proportionate amounts of income of an estate for 1941 were properly credited in 1941 to each of the petitioners within the meaning of section 162 (c) of the Code so that the respective amounts of income so credited are taxable to each of the petitioners in 1941.
1Opinion of the Court
OPINION.
Harron, Judge:
The question in these proceedings is whether the amounts of income for 1941 of the estate of Andrew J. Igoe which were credited to each of the petitioners as of May 31, 1941, in the estate’s books of account were “properly” “credited” within the meaning of section 162 (c) of the Code.1 No other provision of the I. R. C. is involved in the pleadings in this proceeding.
The question is considered upon the evidence which was adduced upon the trial of these proceedings. We may not, and do not, take judicial notice of the record made in this Court upon the trial of the…
2Cases cited4 opinions
- Commissioner of Internal Revenue v. StearnsCourt of Appeals for the Second Circuit · 1933
- Cohen v. CommissionerUnited States Tax Court · 1947
- Igoe v. CommissionerUnited States Tax Court · 1946
- Simon v. HoeyDistrict Court, S.D. New York · 1949
3Cited by4 opinions
- Estate of Johnson v. CommissionerUnited States Tax Court · 1987
- Estate of Johnson v. CommissionerUnited States Tax Court · 1987
- Harris v. United StatesDistrict Court, S.D. West Virginia · 1966
- Igoe v. CommissionerUnited States Tax Court · 1953