Rev. Rul. 55-728

The taxpayer's income includes dividends received from domestic corporations on stock owned individually by him and income received from the estate of his deceased wife, the greater part of which income consists of dividends from stock of domestic corporations held by the estate. Held , in determining the dividend exclusion from gross income as provided by section 116 of the Internal Revenue Code of 1954, a taxpayer is entitled to exclude from gross income dividends from domestic corporations only to the extent that the dividends received do not exceed $50, irrespectively of the fact that such dividends are received from stock owned individually by him and also from stock held by an estate. The dividend income received from such estate which is included in gross income may be considered by the taxpayer in computing the credit against his tax liability allowed by section 34 of the Internal Revenue Code of 1954. Dividend income received from an estate retains the same character in the hands of a beneficiary as in the hands of the estate. Section 662(b) of the 1954 Code