Block v. Commissioner
United States Board of Tax Appeals
1. The estate paid Federal estate taxes prior to 1932 and claimed and was allowed deductions from income for those payments. The applicable state inheritance tax laws were amended after the above mentioned payments and this estate had to pay a large additional state inheritance tax.
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1. The estate paid Federal estate taxes prior to 1932 and claimed and was allowed deductions from income for those payments. The applicable state inheritance tax laws were amended after the above mentioned payments and this estate had to pay a large additional state inheritance tax. This payment increased the credit to which the estate was entitled in connection with its Federal estate tax and, as a result, the estate received a large refund of Federal estate tax in 1932. Held, the Commissioner did not err in including the refund in the income of the estate for the year of recovery. 2.…
1Opinion of the Court
*339OPINION.
Muhdook:
The Commissioner determined a deficiency of $62,--006.88 in income tax of the estate of William H. Block for the calendar year 1932. The parties have settled some of their differences by a stipulation and only two questions require decision by the Board. The first is whether the Commissioner erred in including in the income of the estate for this year the amount of a refund of Federal estate taxes to the estate previously claimed and allowed as a deduction from the income of the estate for the earlier years in which paid. The second is whether the Commissioner erred in failing…
2Cases cited3 opinions
- Burnet v. Sanford & Brooks Co.Supreme Court of the United States · 1931
- Helvering v. ButterworthSupreme Court of the United States · 1933
- Burnet v. WhitehouseSupreme Court of the United States · 1931
3Cited by65 opinions
- Southern Pacific Transp. Co. v. CommissionerUnited States Tax Court · 1980
- Putoma Corp., Successor by Merger of Pro-Mac Company, Petitioners- Cross-Appellants v. Commissioner of Internal Revenue, Cross-AppelleeCourt of Appeals for the Fifth Circuit · 1979
- Alice Phelan Sullivan Corporation, a California Corporation v. The United StatesUnited States Court of Claims · 1967
- Canelo v. CommissionerUnited States Tax Court · 1969
- Mayfair Minerals, Inc. v. CommissionerUnited States Tax Court · 1971
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