Braun v. Commissioner
United States Board of Tax Appeals
1. During the taxable years 1927 and 1928 the taxpayer, a trust estate, paid to the trustees the sum of $75,000 as compensation for personal services in managing two newspaper publishing companies owned by the estate, and also in 1927 paid to the life tenant $150,000 as additional income distributable under decedent's will or in settlement of the life tenant's claim against the estate for additional inncome.
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1. During the taxable years 1927 and 1928 the taxpayer, a trust estate, paid to the trustees the sum of $75,000 as compensation for personal services in managing two newspaper publishing companies owned by the estate, and also in 1927 paid to the life tenant $150,000 as additional income distributable under decedent's will or in settlement of the life tenant's claim against the estate for additional inncome. By the terms of the decedent's will, which created the estate, all the ordinary net income was distributable currently to the life tenant, who paid the tax thereon, and only the capital…
1Opinion of the Court
*1170OX-UNION.
Tkammell:
The first matter of xvhich petitioner complains is the refusal of the respondent to allow as; a deduction from gross income for each of the taxable years 1927 and 1928 the amount of $37,500 paid in each of those years to the trustees for their services in managing, conserving, and operating the two publishing companies. By amendment to the amended petition, petitioner further alleges that, since respondent did not allow these payments as compensation for services rendered, he erred in refusing to take account of the pay*1171ments as additional cost of the stock of the publishing…
2Cases cited6 opinions
- Brewster v. GageSupreme Court of the United States · 1930
- Watson v. CommissionerUnited States Board of Tax Appeals · 1932
- Rice v. BradenSupreme Court of Pennsylvania · 1914
- Piper's EstateSupreme Court of Pennsylvania · 1904
- Harned's EstateSupreme Court of Pennsylvania · 1922
1 more not listed; retrieve them via the Exa API.
3Cited by13 opinions
- Rogers v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1939
- United States v. FairbanksCourt of Appeals for the Ninth Circuit · 1938
- Huntley v. CommissionerUnited States Board of Tax Appeals · 1934
- Felin v. KyleDistrict Court, E.D. Pennsylvania · 1938
- Braun v. CommissionerUnited States Board of Tax Appeals · 1934
8 more not listed; retrieve them via the Exa API.