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