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VAN BUREN v. COMMISSIONER

Docket No. 40380-84.

89 T.C. 1101 (1987)

CAROLINE P. VAN BUREN, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed December 7, 1987.

Attorney(s) appearing for the Case

Richard P. Covey, for the petitioner.

Brian S. Masumoto, Raymond Canals, and Ralph A. Eppensteiner, for the respondent.

OPINION

KÖRNER, Judge:

Respondent determined a deficiency of $15,316.07 in petitioner's 1981 Federal income tax. The issue for our determination is whether the character (as between taxable and tax-exempt income) of amounts reportable by the beneficiary of a simple trust is determined solely by the trust's internally generated income, or whether the character of amounts received by the trust in a distribution...

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