ESTATE OF LONERGAN v. COMMISSIONER

Docket No. 7844.

6 T.C. 715 (1946)

TRUST ESTATE OF THOMAS LONERGAN, ROBERT L. JACKSON, C. P. LEMIRE AND T. H. MASTIN, TRUSTEES, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated April 12, 1946.


Attorney(s) appearing for the Case

James E. Campbell, Esq., for the petitioners.

Gene W. Reardon, Esq., for the respondent.


This proceeding involves an income tax deficiency in the amount of $1,152.49 for the taxable year 1942. The issues are (1) whether Federal income taxes paid by a trust in one year are deductible in the succeeding tax year; (2) whether payments made by the trustees, in the taxable year, in liquidation of a contract indebtedness of decedent, constitute a distribution to a beneficiary within the purview of section 162 (b) of the Internal Revenue Code; and (3) whether attorneys...

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