26 C.F.R. § 1.641
[Reserved]
Notes of Decisions
Cited in 24
cases, 1961–2016 · leading case: Renacci v. Testa (Slip Opinion), 2016 Ohio 3394 (Ohio 2016).
Renacci v. Testa (Slip Opinion), 2016 Ohio 3394 (Ohio 2016). “26 C.F.R. 1.641 (c)—1 (b)(1). The taxpayers’ interpretation of the federal law is precluded by the definition of the “S portion” of the ESBT, which is taxed to the trust.”
Stephenson Trust v. Comm'r, 81 T.C. 283 (Tax Ct. 1983). “Accordingly, respondent determined under sec. 1.641(a)-0(c), Income Tax Regs.”
Est. of Johnson v. Comm'r, 88 T.C. 225 (Tax Ct. 1987). “Commissioner, supra . Where an executor is also named trustee of a trust *234 created under a will, the period of administration continues until the executor completes his administrative duties and assumes his duties as trustee.”
In re Wyly, 552 B.R. 338 (Bankr. N.D. Tex. 2016). “1277 26 C.F.R. § 1.641 (a)-0 indicates that § 643 has “no application to any portion of the corpus or income of a trust which is to-be regarded, within the meaning of the Code, as that of the grantor or others treated as its substantial owners.”
Est. of Papson v. Comm'r, 73 T.C. 290 (Tax Ct. 1979). “The period of administration was not unduly prolonged under respondent's regulations ( sec.”
CHM Co. v. Comm'r, 68 T.C. 31 (Tax Ct. 1977). “We shall first turn our attention to the question whether, for purposes of subchapter S, an entity separate and apart from the shareholder is created when a shareholder files a chapter XI or chapter XII petition.”
Miller v. Comm'r, 39 T.C. 940 (Tax Ct. 1963). “The first issue is whether, as respondent argues, the administration of the estate of Addison Miller should have been terminated sometime prior to 1956, in which event the income reported by the estate in the years 1956 and 1957 would be includable in the petitioner's income for…”
Costello v. Comm'r, 2016 T.C. Memo. 33 (Tax Ct. 2016). “Moreover, the termination of a trust does not depend "upon the technicality of whether or not the trustee has rendered his final accounting", sec.”
Maresca Trust v. Comm'r, 46 T.C.M. 1147 (Tax Ct. 1983). “, which states: The period of administration or settlement *295 is the period actually required by the administrator or executor to perform the ordinary duties of administration, such as the collection of assets and the payment of debts, taxes, legacies, and bequests, whether…”
Petersen v. Comm'r, 35 T.C. 962 (Tax Ct. 1961). “*973 In support of this argument respondent relies on section 1.”
Dorfman v. Comm'r, 48 T.C. 478 (Tax Ct. 1967). “Section 443 provides that a return for a period of less than 12 months shall be made when the taxpayer is in existence during only part of what would otherwise be his taxable year. The regulation in question cannot be considered unreasonable in the light of these provisions of…”
Dominion Trust Co. of Tennessee v. United States, 786 F. Supp. 1321 (M.D. Tenn. 1991). “26 C.F.R. § 1.641 (a)-2. Capital gains income is included in gross income.”
— 26 C.F.R. § 1.641(A) — 2 cases
Stephenson Trust v. Comm'r, 81 T.C. 283 (Tax Ct. 1983). “Accordingly, respondent determined under sec. 1.641(a)-0(c), Income Tax Regs.”
Est. of Duncan v. Comm'r, 2011 T.C. Memo. 255 (Tax Ct. 2011).
— 26 C.F.R. § 1.641(B) — 16 cases
Est. of Johnson v. Comm'r, 88 T.C. 225 (Tax Ct. 1987). “Commissioner, supra . Where an executor is also named trustee of a trust *234 created under a will, the period of administration continues until the executor completes his administrative duties and assumes his duties as trustee.”
Est. of Papson v. Comm'r, 73 T.C. 290 (Tax Ct. 1979). “The period of administration was not unduly prolonged under respondent's regulations ( sec.”
CHM Co. v. Comm'r, 68 T.C. 31 (Tax Ct. 1977). “We shall first turn our attention to the question whether, for purposes of subchapter S, an entity separate and apart from the shareholder is created when a shareholder files a chapter XI or chapter XII petition.”
Miller v. Comm'r, 39 T.C. 940 (Tax Ct. 1963). “The first issue is whether, as respondent argues, the administration of the estate of Addison Miller should have been terminated sometime prior to 1956, in which event the income reported by the estate in the years 1956 and 1957 would be includable in the petitioner's income for…”
Costello v. Comm'r, 2016 T.C. Memo. 33 (Tax Ct. 2016). “Moreover, the termination of a trust does not depend "upon the technicality of whether or not the trustee has rendered his final accounting", sec.”
— 26 C.F.R. § 1.641(c) — 1 case
Renacci v. Testa (Slip Opinion), 2016 Ohio 3394 (Ohio 2016). “26 C.F.R. 1.641 (c)—1 (b)(1). The taxpayers’ interpretation of the federal law is precluded by the definition of the “S portion” of the ESBT, which is taxed to the trust.”
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