T.C. Memo. 1996-447
UNITED STATES TAX COURT
JONATHAN B. GEFTMAN, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 22392-91. Filed September 30, 1996.
D's will formed 3 trusts: Trust A, Trust B, and
Trust C. P was the sole beneficiary of Trust C. Trust
C distributed $46,936 to P during his 1985 taxable
year. Trust C's distributable net income consisted of
taxable income and tax-exempt income.
1. Held: P's gross income includes a portion of
the distribution based on the ratio between the taxable
items and the nontaxable items making up Trust C's
distributable net income.
2. Held, further, P is liable for the addition
to tax under sec. 6651(a), I.R.C.
3. Held, further, P is liable for the addition
to tax under sec. 6654(a), I.R.C.
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