Legal Opinion

Tiefenbrunn v. Commissioner

United States Tax Court

Decided September 29, 1980No. Docket Nos. 5786-78, 5787-78Published

Petitioners are income beneficiaries and remaindermen of T, a simple testamentary trust, which owned land and a building in New Haven, Conn. T's New Haven property was taken by condemnation in 1968. The Connecticut Superior Court in 1971 awarded T $ 1,700,000 for the taking of its property, plus $ 103,912.76 in "interest."

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Petitioners are income beneficiaries and remaindermen of T, a simple testamentary trust, which owned land and a building in New Haven, Conn. T's New Haven property was taken by condemnation in 1968. The Connecticut Superior Court in 1971 awarded T $ 1,700,000 for the taking of its property, plus $ 103,912.76 in "interest." In 1969 and 1972, T purchased real property with a total cost in excess of the amounts received pursuant to the judgment of the Superior Court. 1. Held, the "interest" received as part of the condemnation award is includable in T's 1971 income and taxable to the petitioners…

1Opinion of the Court

Elizabeth R. Tiefenbrunn, Petitioner v. Commissioner of Internal Revenue, Respondent; Alan Roessler and Virginia Roessler, Petitioners v. Commissioner of Internal Revenue, Respondent

Tiefenbrunn v. Commissioner

Docket Nos. 5786-78, 5787-78

United States Tax Court

74 T.C. 1566; 1980 U.S. Tax Ct. LEXIS 49;

September 29, 1980, Filed

Decisions to be entered under Rule 155.

Petitioners are income beneficiaries and remaindermen of T, a simple testamentary trust, which owned land and a building in New Haven, Conn. T's New Haven property was taken by condemnation in 1968. The Connecticut Superior Court in…

2Cases cited19 opinions

  1. Kieselbach v. CommissionerSupreme Court of the United States · 1943
  2. Edgar v. CommissionerUnited States Tax Court · 1971
  3. Lucile McAulay Filippini, as of the Last Will and Testament of Carra McAulay Deceased v. United StatesCourt of Appeals for the Ninth Circuit · 1963
  4. Isaac G. Johnson & Co. v. United StatesCourt of Appeals for the Second Circuit · 1945
  5. Smith v. CommissionerUnited States Tax Court · 1972

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