Dorfman v. Commissioner
United States Tax Court
The petitioner, Annette Dorfman, was the remainderman of two trusts which terminated in 1956. At the time of their termination, the trusts had unused capital loss carryovers under sec. 1212 of the Internal Revenue Code of 1954 from their taxable year 1955. Sec. 1212, as applicable to the year in question, provided for the carryover of a net capital loss for any taxable year to the 5 succeeding taxable years.
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The petitioner, Annette Dorfman, was the remainderman of two trusts which terminated in 1956. At the time of their termination, the trusts had unused capital loss carryovers under sec. 1212 of the Internal Revenue Code of 1954 from their taxable year 1955. Sec. 1212, as applicable to the year in question, provided for the carryover of a net capital loss for any taxable year to the 5 succeeding taxable years. Sec. 642(h) of the Code provides that if, on the termination of a trust, the trust has an unused capital loss carryover under sec. 1212, then such carryover shall be allowed as a…
1Opinion of the Court
Nat Dorfman and Annette Dorfman, Petitioners v. Commissioner of Internal Revenue, Respondent
Dorfman v. Commissioner
Docket No. 4292-64
United States Tax Court
48 T.C. 478; 1967 U.S. Tax Ct. LEXIS 78;
June 28, 1967, Filed
Decision will be entered under Rule 50.
The petitioner, Annette Dorfman, was the remainderman of two trusts which terminated in 1956. At the time of their termination, the trusts had unused capital loss carryovers under sec. 1212 of the Internal Revenue Code of 1954 from their taxable year 1955. Sec. 1212, as applicable to the year in question, provided for the carryover of a net…
2Cases cited6 opinions
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- Fawcus MacHine Co. v. United StatesSupreme Court of the United States · 1931
- Boske v. ComingoreSupreme Court of the United States · 1900
- Neave v. CommissionerUnited States Tax Court · 1952
- Westphal v. CommissionerUnited States Tax Court · 1961
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