Legal Opinion

Bibby v. Commissioner

United States Tax Court

Decided July 26, 1965No. Docket No. 4903-63Published

Income of a trust established by petitioners is taxable to them because the trust failed to satisfy the requirements of section 673(a), I.R.C. 1954.

1Opinion of the Court

C. O. Bibby and Marie Bibby, Petitioners, v. Commissioner of Internal Revenue, Respondent

Bibby v. Commissioner

Docket No. 4903-63

United States Tax Court

44 T.C. 638; 1965 U.S. Tax Ct. LEXIS 49;

July 26, 1965, Filed

Decision will be entered under Rule 50.

Income of a trust established by petitioners is taxable to them because the trust failed to satisfy the requirements of section 673(a), I.R.C. 1954.

Leslie C. Hackler, Jr., for the petitioners.

James F. Hart, for the respondent.

Train, Judge.

TRAIN

Respondent determined deficiencies in petitioners' income taxes as follows:

Year ended --

Deficiency

Feb.…

2Cases cited6 opinions

  1. Miller v. CommissionerUnited States Tax Court · 1946
  2. Stoddard v. EatonDistrict Court, D. Connecticut · 1927
  3. Garcia v. Garcia De OrtizCourt of Appeals of Texas · 1953
  4. Bibby v. CommissionerUnited States Tax Court · 1965
  5. Reizenstein v. CommissionerUnited States Tax Court · 1954

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