Roosevelt & Son Inv. Fund v. Commissioner
United States Board of Tax Appeals
For the years 1927 and 1928 taxpayer filed fiduciary returns on form 1041. Despite a ruling by the Commissioner in 1929 that it was taxable as a corporation, taxpayer on March 15, 1930, again filed a fiduciary return, giving all information requisite for assessing the tax either as a trust or as a corporation.
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For the years 1927 and 1928 taxpayer filed fiduciary returns on form 1041. Despite a ruling by the Commissioner in 1929 that it was taxable as a corporation, taxpayer on March 15, 1930, again filed a fiduciary return, giving all information requisite for assessing the tax either as a trust or as a corporation. On October 17, 1930, the Commissioner advised that on reconsideration it was held that taxpayer was a strict trust for the years 1927 and 1928, and on November 11, 1930, pursuant to request for a further ruling, advised that if the conditions had not changed the same ruling would be…
1Opinion of the Court
ROOSEVELT & SON INVESTMENT FUND, GEORGE E. ROOSEVELT, PHILIP J. ROOSEVELT, FAIRMAN R. DICK, ERMAND J. RIFFLARD AND VAN S. MERLE SMITH, AS MANAGERS, AND CHEMICAL BANK & TRUST COMPANY (FORMERLY THE CHEMICAL NATIONAL BANK OF NEW YORK), AS TRUSTEE, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Roosevelt & Son Inv. Fund v. Commissioner
Docket No. 76196.
United States Board of Tax Appeals
34 B.T.A. 38; 1936 BTA LEXIS 757;
March 6, 1936, Promulgated
For the years 1927 and 1928 taxpayer filed fiduciary returns on form 1041. Despite a ruling by the Commissioner in 1929 that it was taxable as…
2Cases cited10 opinions
- Zellerbach Paper Co. v. HelveringSupreme Court of the United States · 1934
- Lucas v. Pilliod Lumber Co.Supreme Court of the United States · 1930
- United States v. First National Pictures, Inc.Supreme Court of the United States · 1930
- Mabel Elevator Co. v. CommissionerUnited States Board of Tax Appeals · 1925
- In re MatthewsDistrict Court, W.D. Arkansas · 1901
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