Legal Opinion

Hormel v. Commissioner

United States Board of Tax Appeals

Decided February 29, 1932No. Docket Nos. 34765-34767, 44967-44969, 55631, 55632PublishedCited by 3 opinions

1. The evidence is insufficient to establish what portion, if any, of the income received by certain beneficiaries of a trust represents taxes thereon. 2. In the circumstances herein amounts received by the petitioners taxes thereon. as beneficiaries of a trust can not be identified as dividends received from domestic corporations for the purpose of allowing credit in computing income subject to normal tax.

1Opinion of the Court

OPINION.

Lansdon :

The respondent has asserted deficiencies in income taxes for the years and in the amounts as follows:

[[Image here]]

The deficiencies arise from the respondent’s determination that amounts received by the petitioners on “ operators’ shares ” in the Hormel Trust constitute income taxable at both the normal and surtax rates.

George A. Hormel and Jay C. Hormel, who were the principal stockholders of George A. Hormel and Company, a Minnesota corporation, hereinafter referred to as the Company, transferred 14,410 shares of common stock of the Company in trust for the purpose, as…

2Cited by3 opinions

  1. Prouty v. CommissionerUnited States Board of Tax Appeals · 1934
  2. Hormel v. CommissionerUnited States Board of Tax Appeals · 1932
  3. Prouty v. CommissionerUnited States Board of Tax Appeals · 1934

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API