Bedell v. Commissioner
United States Tax Court
Held, the testamentary trust herein did not have "associates", and therefore could not be classified as an "association" taxable as a corporation. Sec. 7701(a)(3), I.R.C. 1954; sec. 301.7701-2(a)(2) and (3), Proced. & Admin. Regs.
1Opinion of the Court
RAUM, Judge:
The Commissioner determined deficiencies in petitioners’ income tax in the following amounts:
Docket No. Petitioner 1980 1981
21381-84 Harry M. Bedell, Jr. — $810.00
21382-84 Bedell Trust $17,857.73 15,021.48
The issue presented for decision is whether the Estate of Harry M. Bedell, Sr., Trust (the trust or the Bedell Trust)1 is properly taxable as a trust, or classified as an association taxable as a corporation.2 The resolution of this one issue will dictate the proper tax treatment to the trust of income earned by it and distributions to beneficiaries made by it in 1980 and 1981.…
2Cases cited11 opinions
- Morrissey v. CommissionerSupreme Court of the United States · 1935
- Helvering v. Coleman-Gilbert AssociatesSupreme Court of the United States · 1935
- Swanson v. CommissionerSupreme Court of the United States · 1935
- Foster v. Comm'rUnited States Tax Court · 1983
- Helvering v. CombsSupreme Court of the United States · 1935
6 more not listed; retrieve them via the Exa API.
3Cited by6 opinions
- Estate of Allen v. CommissionerUnited States Tax Court · 1989
- Allen v. CommissionerUnited States Tax Court · 1991
- Bedell v. CommissionerUnited States Tax Court · 1986
- Rost v. United StatesCourt of Appeals for the Fifth Circuit · 2022
- Rost v. United StatesCourt of Appeals for the Fifth Circuit · 2022
1 more not listed; retrieve them via the Exa API.