Aaron v. Commissioner
United States Tax Court
1. Petitioner received all the assets of her deceased husband's estate upon its final distribution, except for $ 150,000 in Treasury notes and $ 19,428.66 in cash which, pursuant to an order of the Probate Court, were placed in a trust to be available for the payment of the estate's undetermined tax liabilities.
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1. Petitioner received all the assets of her deceased husband's estate upon its final distribution, except for $ 150,000 in Treasury notes and $ 19,428.66 in cash which, pursuant to an order of the Probate Court, were placed in a trust to be available for the payment of the estate's undetermined tax liabilities. The estate had a net income of $ 86,193.61 in its final year of administration, and respondent determined that such income was included in the assets distributed to petitioner and taxable to her rather than to the estate. Held, respondent is sustained since petitioner has failed to…
1Opinion of the Court
OPINION.
Rice,- Judge:
Tbis proceeding involves a deficiency in income tax determined against Wilma Aaron (hereinafter referred to as the petitioner) in the amount of $111,069.74 for tbe year 1946.
The issues to be decided .are: (1) Whether the income of the estate of Alfred H. Massera for the period from J anuary 1,1946, to August 9,1946, is includible in petitioner’s income for 1946, that being the year in which the estate’s administration terminated and its residual assets were distributed to petitioner as its sole beneficiary; (2) whether any part of the income taxes paid by petitioner to…
2Cases cited4 opinions
- Carlisle v. CommissionerCourt of Appeals for the Sixth Circuit · 1948
- Carlisle v. CommissionerUnited States Tax Court · 1947
- Harris v. CommissionerUnited States Tax Court · 1948
- Jones v. CommissionerUnited States Tax Court · 1943
3Cited by15 opinions
- Redlark v. Comm'rUnited States Tax Court · 1996
- Reise v. CommissionerUnited States Tax Court · 1961
- Robinson v. Comm'rUnited States Tax Court · 2002
- Allen v. United StatesDistrict Court, E.D. North Carolina · 1997
- Delmar v. CommissionerUnited States Tax Court · 1956
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