Sneed v. Commissioner
United States Tax Court
1. Income -- Community Property -- Estate During Period of Administration -- Section 161 (a) (3). -- A deceased husband's estate is taxable upon only one-half of the income derived during administration from Texas community property. 2. Deduction -- Estate -- Legacy Payable from Income Only -- Section 162 (c). -- An amount payable annually to the widow, which by the terms of the will of the decedent is to come solely from income of the estate, is deductible by the estate…
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1. Income -- Community Property -- Estate During Period of Administration -- Section 161 (a) (3). -- A deceased husband's estate is taxable upon only one-half of the income derived during administration from Texas community property. 2. Deduction -- Estate -- Legacy Payable from Income Only -- Section 162 (c). -- An amount payable annually to the widow, which by the terms of the will of the decedent is to come solely from income of the estate, is deductible by the estate under section 162 (c).
1Opinion of the Court
OPINION.
Murdock, Judge:
The Commissioner determined deficiencies of $2,837.54 for 1940 and $36,200.61 for 1941 in the income tax of the petitioner. The two issues for decision are whether the petitioner, the estate of the deceased husband, must report all of the income from Texas community property during the period of administration and whether the petitioner is entitled to deduct, as distributable income, amounts distributed in each year to Brad Love Sneed, widow of the decedent. The facts have been stipulated.
J. T. Sneed, Jr., the husband of Brad Love Sneed, died testate on October 15,…
2Cases cited5 opinions
- Henderson's Estate v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1946
- Barbour v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1937
- Bishop v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1945
- Blackburn's Estate v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1950
- Sneed v. PoolCourt of Appeals of Texas · 1950
3Cited by21 opinions
- United States v. MerrillCourt of Appeals for the Ninth Circuit · 1954
- Sneed v. CommissionerCourt of Appeals for the Fifth Circuit · 1955
- Hargis v. CommissionerUnited States Tax Court · 1953
- Petersen v. CommissionerUnited States Tax Court · 1961
- Estate of Machat v. CommissionerUnited States Tax Court · 1998
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