Procter v. Commissioner
United States Tax Court
Held, petitioner is not entitled to deductions on account of amounts paid to acquire defeasible remainder interests of her son in certain trusts which interests were divested by reason of her son's death during the taxable year. The remainder interests were not acquired in transactions "entered into for profit" within section 23 (e) (2), I. R. C., nor was the son's death an "other casualty" within section 23 (e) (3), I. R. C.
1Opinion of the Court
Lillian S. Procter, Petitioner, v. Commissioner of Internal Revenue, Respondent
Procter v. Commissioner
Docket No. 31320
United States Tax Court
19 T.C. 387; 1952 U.S. Tax Ct. LEXIS 28;
December 4, 1952, Promulgated
Decision will be entered for the respondent.
Held, petitioner is not entitled to deductions on account of amounts paid to acquire defeasible remainder interests of her son in certain trusts which interests were divested by reason of her son's death during the taxable year. The remainder interests were not acquired in transactions "entered into for profit" within section 23 (e) (2), I. R.…
2Cases cited6 opinions
- Seidler v. CommissionerUnited States Tax Court · 1952
- Early v. AtkinsonCourt of Appeals for the Fourth Circuit · 1949
- Smith v. CommissionerUnited States Tax Court · 1948
- Helvering v. LouisCourt of Appeals for the D.C. Circuit · 1935
- Thomas v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1938
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