Estate of Movius v. Commissioner

OPINION.

BRuce, Judge:

In each of the statements accompanying the notices of deficiencies herein, respondent explained the adjustments giving rise to the deficiencies as follows:

It is held that no deduction is allowable under Section 28 (c) of the Internal Revenue Code for taxes paid on real property held in trust for you, legal title to which is in the trustees.

Petitioners contend that the funds accumulated for the payment of taxes under the permission and direction of the two beneficiaries, being distributable to them and being applied by their direction to payment of taxes to protect…