Dileonardo v. Commissioner
United States Tax Court
P is a one-sixth income beneficiary of a trust. In State court, P filed objections to an accounting by the trustee. The State court (1) ruled against P, (2) required P to compensate the trustee, the other beneficiaries, and a guardian ad litem for their expenses in dealing with P's objections, and (3) directed the trustee to use P's share of the trust distributions to accomplish this compensation.
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P is a one-sixth income beneficiary of a trust. In State court, P filed objections to an accounting by the trustee. The State court (1) ruled against P, (2) required P to compensate the trustee, the other beneficiaries, and a guardian ad litem for their expenses in dealing with P's objections, and (3) directed the trustee to use P's share of the trust distributions to accomplish this compensation. P reported as income her share of the trust's income and deducted the court-ordered payments. HELD: The origin and character of the claim resulting in P's payments was the trustee's filing of an…
1Opinion of the Court
SHARON PURCELL DILEONARDO, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Dileonardo v. Commissioner
No. 5508-97
United States Tax Court
T.C. Memo 2000-120; 2000 Tax Ct. Memo LEXIS 136; 79 T.C.M. (CCH) 1820;
April 5, 2000, Filed
Decision will be entered for petitioner.
P is a one-sixth income beneficiary of a trust. In State
court, P filed objections to an accounting by the trustee. The
State court (1) ruled against P, (2) required P to compensate
the trustee, the other beneficiaries, and a guardian ad litem
for their expenses in dealing with P's objections, and (3)
directed the trustee to…
2Cases cited27 opinions
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Helvering v. TaylorSupreme Court of the United States · 1935
- United States v. GilmoreSupreme Court of the United States · 1963
- Trust Under the Will of Bingham v. CommissionerSupreme Court of the United States · 1945
- Commissioner v. TellierSupreme Court of the United States · 1966
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