Legal Opinion

Armstrong v. Commissioner

United States Board of Tax Appeals

Decided September 29, 1938No. Docket No. 82552Published

Petitioner was the life beneficiary of a testamentary trust created by her husband which, in the taxable year in question, received $88,200,35 interest which had been accrued but unpaid on certain notes held by the trust.

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Petitioner was the life beneficiary of a testamentary trust created by her husband which, in the taxable year in question, received $88,200,35 interest which had been accrued but unpaid on certain notes held by the trust. The executors of the estate theretofore had received the notes as a principal asset of the estate, and had transferred one of them of the face amount of $25,000, plus interest, for the sum of $26,522.30, which sum was entered in their books and reported by them as income when received. In lieu of the note thus transferred the executors placed in their principal account an…

1Opinion of the Court

SUSAN B. ARMSTRONG, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Armstrong v. Commissioner

Docket No. 82552.

United States Board of Tax Appeals

38 B.T.A. 658; 1938 BTA LEXIS 840;

September 29, 1938, Promulgated

Petitioner was the life beneficiary of a testamentary trust created by her husband which, in the taxable year in question, received $88,200,35 interest which had been accrued but unpaid on certain notes held by the trust. The executors of the estate theretofore had received the notes as a principal asset of the estate, and had transferred one of them of the face amount of…

2Cases cited3 opinions

  1. Blair v. CommissionerSupreme Court of the United States · 1937
  2. Freuler v. HelveringSupreme Court of the United States · 1934
  3. Armstrong v. CommissionerUnited States Board of Tax Appeals · 1938

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