Tiefenbrunn v. Commissioner
United States Tax Court
Petitioners are income beneficiaries and remaindermen of T, a simple testamentary trust, which owned land and a building in New Haven, Conn. T's New Haven property was taken by condemnation in 1968. The Connecticut Superior Court in 1971 awarded T $ 1,700,000 for the taking of its property, plus $ 103,912.76 in "interest."
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Petitioners are income beneficiaries and remaindermen of T, a simple testamentary trust, which owned land and a building in New Haven, Conn. T's New Haven property was taken by condemnation in 1968. The Connecticut Superior Court in 1971 awarded T $ 1,700,000 for the taking of its property, plus $ 103,912.76 in "interest." In 1969 and 1972, T purchased real property with a total cost in excess of the amounts received pursuant to the judgment of the Superior Court. 1. Held, the "interest" received as part of the condemnation award is includable in T's 1971 income and taxable to the petitioners…
1Opinion of the Court
OPINION
Raum, Judge:1
The Commissioner determined deficiencies in petitioners’ income taxes as set forth below: 2
1971 1973
Elizabeth R. Tiefenbrunn. $7,397.09 $3,303.97
Alan Roessler and Virginia Roessler. 8,027.77 3,823.00
Petitioners Elizabeth Tiefenbrunn and Alan Roessler are two of the life income beneficiaries of the Carl Roessler Trust (the trust). The stipulation of the parties has already disposed of a number of matters in controversy, but the following two issues remain for decision: (1) Whether “interest” awarded the trust in 1971 pursuant to a judgment determining the amount of just…
2Cases cited18 opinions
- Kieselbach v. CommissionerSupreme Court of the United States · 1943
- Edgar v. CommissionerUnited States Tax Court · 1971
- Lucile McAulay Filippini, as of the Last Will and Testament of Carra McAulay Deceased v. United StatesCourt of Appeals for the Ninth Circuit · 1963
- Isaac G. Johnson & Co. v. United StatesCourt of Appeals for the Second Circuit · 1945
- Smith v. CommissionerUnited States Tax Court · 1972
13 more not listed; retrieve them via the Exa API.
3Cited by12 opinions
- Kovacs v. CommissionerUnited States Tax Court · 1993
- Aames v. CommissionerUnited States Tax Court · 1990
- Fulks v. CommissionerUnited States Tax Court · 1989
- RJR Nabisco v. CommissionerUnited States Tax Court · 1998
- Delgado v. CommissionerUnited States Tax Court · 1988
7 more not listed; retrieve them via the Exa API.