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.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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