MELLON v. COMMISSIONER

Docket Nos. 13813, 15145, 15146, 15147.

11 T.C. 135 (1948)

WILLIAM L. MELLON, JR. AND MELLON NATIONAL BANK AND TRUST COMPANY (SUCCESSOR BY MERGER AND CONSOLIDATION TO THE UNION TRUST COMPANY OF PITTSBURGH), TRUSTEES UNDER DEED OF TRUST OF WILLIAM L. MELLON DATED NOVEMBER 17, 1941, FOR WILLIAM L. MELLON, JR. AND OTHERS, PETITIONER, ET AL. v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated August 5, 1948.


Attorney(s) appearing for the Case

William F. Knox, Esq., for the petitioners.

Hobby H. McCall, Esq., for the respondent.


OPINION.

DISNEY, Judge:

Each of the proceedings herein involves deficiencies of $474.83 and $280.25 in income tax for the taxable period January 1, 1942, to November 30, 1942, and for the fiscal year ended November 30, 1943, respectively. The common issue is whether income for each taxable period in excess of the amount distributed to the primary beneficiary is deductible from the gross income of the trust. Except for income tax returns, all of the...

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