Coleman Trust v. Commissioner
United States Tax Court
The individual taxpayer in these proceedings was made the income beneficiary for life of a trust which her husband created in 1934. She was to receive the entire net income of the trust each year. In case the income from the trust in any year was less than $ 12,000, the trustees were directed to pay to the beneficiary upon her written request enough out of the principal of the trust estate to make up the full $ 12,000 per annum.
Read the full summary
The individual taxpayer in these proceedings was made the income beneficiary for life of a trust which her husband created in 1934. She was to receive the entire net income of the trust each year. In case the income from the trust in any year was less than $ 12,000, the trustees were directed to pay to the beneficiary upon her written request enough out of the principal of the trust estate to make up the full $ 12,000 per annum. In the three taxable years involved in these proceedings, the income of the trust was not sufficient to pay the beneficiary $ 12,000 per annum and upon her written…
1Opinion of the Court
OPINION.
Black, Judge:
These cases have been consolidated. Docket No. 1585 involves deficiencies in income tax which the Commissioner has determined against the Horace C. Coleman Trust as follows:
1938_ $0. 33
1939_ 932. 97
1910_1,144. 04
Docket No. 1586 involves deficiencies in income tax which the Commissioner has determined against Helen W. Coleman as follows:
1938-$350. 96
1939_ 629.33
1940- 391.33
The deficiencies in Docket No. 1586 result from adjustments which the Commissioner made in the income tax return of Helen W. Coleman. which she does not contest. However, she claims an overpayment in…
2Cases cited3 opinions
- Helvering v. ButterworthSupreme Court of the United States · 1933
- Burnet v. WhitehouseSupreme Court of the United States · 1931
- Frankel v. CommissionerUnited States Tax Court · 1944
3Cited by6 opinions
- Coleman v. CommissionerCourt of Appeals for the Third Circuit · 1945
- Curry v. CommissionerUnited States Tax Court · 1945
- Northern Trust Co. v. CommissionerUnited States Tax Court · 1945
- Coleman Trust v. CommissionerUnited States Tax Court · 1944
- Northern Trust Co. v. CommissionerUnited States Tax Court · 1945
1 more not listed; retrieve them via the Exa API.