Legal Opinion

Ullmann v. Commissioner

United States Board of Tax Appeals

Decided May 17, 1934No. Docket Nos. 56470-56472Published

1. Payments made to American nationals pursuant to an award of the Mixed Claims Commission, United States and Germany, are not gifts. 2. All American national whose property had been sequestered by the German Government and to whom the Mixed Claims Commission, United States and Germany, made an award, may not be taxed on payments made pursuant thereto until his capital has been made whole.

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1. Payments made to American nationals pursuant to an award of the Mixed Claims Commission, United States and Germany, are not gifts. 2. All American national whose property had been sequestered by the German Government and to whom the Mixed Claims Commission, United States and Germany, made an award, may not be taxed on payments made pursuant thereto until his capital has been made whole. James Speyer,30 B.T.A. 517. 3. Payments which probably never will be received should not be accrued for income tax purposes. 4. Attorney fees paid for services rendered in the prosecution of a claim before…

1Opinion of the Court

EMANUEL SOLOMON ULLMANN, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

JOSEPH ULLMANN, JR., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

JOSEPH ULLMANN, JR., AND THERESA ULLMANN, AS EXECUTORS OF THE ESTATE OF SAMUEL ULLMANN, DECEASED, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Ullmann v. Commissioner

Docket Nos. 56470-56472.

United States Board of Tax Appeals

30 B.T.A. 764; 1934 BTA LEXIS 1276;

May 17, 1934, Promulgated

1. Payments made to American nationals pursuant to an award of the Mixed Claims Commission, United States and Germany, are not gifts.

2…

2Cases cited10 opinions

  1. United States v. S. S. White Dental Manufacturing Co.Supreme Court of the United States · 1927
  2. Comegys v. VasseSupreme Court of the United States · 1828
  3. Phelps v. McDonaldSupreme Court of the United States · 1879
  4. Williams v. HeardSupreme Court of the United States · 1891
  5. Great Northern Railway Co. v. CommissionerUnited States Board of Tax Appeals · 1927

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