Legal Opinion

Estate of Esposito v. Commissioner

United States Tax Court

Decided May 31, 1963No. Docket No. 92346Published

Charitable Deduction -- Consent Dividend Under Sec. 565, I.R.C. 1954. -- An amount reported as 1957 income by the petitioner by consent under section 565, which amount it never received or accounted for as income in the administration of the estate but, if received, was received and accounted for as principal of the estate, was not shown to be properly a part of a charitable deduction for 1957.

1Opinion of the Court

Estate of Joseph R. Esposito, Erwin Bruce Hallett, James Beckett and Russell Gowans, Executors, Petitioner, v. Commissioner of Internal Revenue, Respondent

Estate of Esposito v. Commissioner

Docket No. 92346

United States Tax Court

40 T.C. 459; 1963 U.S. Tax Ct. LEXIS 110;

May 31, 1963, Filed

Decision will be entered under Rule 50.

Charitable Deduction -- Consent Dividend Under Sec. 565, I.R.C. 1954. -- An amount reported as 1957 income by the petitioner by consent under section 565, which amount it never received or accounted for as income in the administration of the estate but, if received, was…

2Cases cited3 opinions

  1. Bowers v. SlocumCourt of Appeals for the Second Circuit · 1927
  2. Leon A. Beeghly Fund v. CommissionerUnited States Tax Court · 1960
  3. Estate of Esposito v. CommissionerUnited States Tax Court · 1963

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