Title Guarantee & Trust Co. v. Commissioner
United States Board of Tax Appeals
1. On the date of decedent's death a trust established for her benefit owned corporate bonds upon which interest was due. The interest was subsequently collected and credited to trust income. Return filed on behalf of decedent for the taxable period immediately preceding her death did not include in gross income the interest accrued upon the bonds on the date of death.
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1. On the date of decedent's death a trust established for her benefit owned corporate bonds upon which interest was due. The interest was subsequently collected and credited to trust income. Return filed on behalf of decedent for the taxable period immediately preceding her death did not include in gross income the interest accrued upon the bonds on the date of death. Held, under the facts, that no such substantial doubt as to the collectibility of the interest existed on the date of the death of the decedent as to justify its exclusion from gross income. 2. Decedent's husband, four months…
1Opinion of the Court
*478OPINION.
Mellott:
Section 42 of the Bevenue Act of 19341 requires that amounts accrued up to the date of the death of a decedent be included in computing his net income for the taxable period in which falls the date of his death. Pursuant to this section the respondent has included in decedent’s income for the period from January 1 to March 16,1934, the interest upon the Prudence Co. bonds. Some of the interest, as shown by our findings, was represented by coupons due but unpaid and some by coupons attached to bonds in the trust estate but which were not yet due. The parties upon brief make no…
2Cases cited6 opinions
- Eisner v. MacOmberSupreme Court of the United States · 1920
- North American Oil Consolidated v. BurnetSupreme Court of the United States · 1932
- Burnet v. LoganSupreme Court of the United States · 1931
- Irwin v. GavitSupreme Court of the United States · 1925
- Helvering v. ButterworthSupreme Court of the United States · 1933
1 more not listed; retrieve them via the Exa API.
3Cited by8 opinions
- Waller v. CommissionerUnited States Tax Court · 1963
- United States v. ArcherCourt of Appeals for the First Circuit · 1949
- Bach v. RothensiesDistrict Court, E.D. Pennsylvania · 1941
- Gillespie v. CommissionerUnited States Board of Tax Appeals · 1941
- Manne v. CommissionerUnited States Tax Court · 1945
3 more not listed; retrieve them via the Exa API.