Legal Opinion

Copeland v. Commissioner

United States Tax Court

Decided June 9, 1949No. Docket No. 18233Published

Gross Income -- Bequest -- Annuity -- Payable at Intervals -- Income from Property -- Section 22 (b) (3). -- An annuity payable quarterly and actually paid entirely out of income from property of the testamentary trust is taxable to the beneficiary under section 22 (b) (3), I. R. C.

1Opinion of the Court

Raye E. Copeland, Petitioner, v. Commissioner of Internal Revenue, Respondent

Copeland v. Commissioner

Docket No. 18233

United States Tax Court

12 T.C. 1020; 1949 U.S. Tax Ct. LEXIS 170;

June 9, 1949, Promulgated

Decision will be entered for the respondent.

Gross Income -- Bequest -- Annuity -- Payable at Intervals -- Income from Property -- Section 22 (b) (3). -- An annuity payable quarterly and actually paid entirely out of income from property of the testamentary trust is taxable to the beneficiary under section 22 (b) (3), I. R. C.

D. Hays Solis-Cohen, Esq., for the petitioner.

John A. Newton,…

2Cases cited2 opinions

  1. Townsend v. CommissionerUnited States Tax Court · 1949
  2. Copeland v. CommissionerUnited States Tax Court · 1949

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