Jonathan B. Geftman - Page 1

                                 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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