Legal Opinion
Funk v. Commissioner of Internal Revenue
Court of Appeals for the Third Circuit
Decided November 16, 1950No. 10216_1PublishedCited by 24 opinions
1Opinion of the Court
KALODNER, Circuit Judge.
The only substantial issue presented on this petition to review the decision of the Tax Court is whether there is taxable to the taxpayer under Section 22(a) of the Internal Revenue Code, 26 U.S.C.A. Section 22(a), 1 the income of four trusts of which she was the sole trustee in the taxable years 1938 to 1941 here involved. The trusts were created by the taxpayer’s husband.
The Tax Court, four judges dissenting, held that the income of the trusts, without regard to the distributions made by the taxpayer, is taxable to her. 14 T.C. 198.
The details of the creation of the…
2Cases cited15 opinions
- Helvering v. CliffordSupreme Court of the United States · 1940
- Funk v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1947
- Mallinckrodt v. NunanCourt of Appeals for the Eighth Circuit · 1945
- Stix v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1945
- Coffin v. WatsonNew Jersey Court of Chancery · 1911
10 more not listed; retrieve them via the Exa API.
3Cited by24 opinions
- Fred Brown v. Blue Cross and Blue Shield of Alabama, Inc.Court of Appeals for the Eleventh Circuit · 1990
- Stiller v. StateTennessee Supreme Court · 1974
- Smith v. First Community Bancshares, Inc.West Virginia Supreme Court · 2002
- Commission of Internal Revenue v. Dwight's EstateCourt of Appeals for the Second Circuit · 1953
- Peoples Trust Company Of Bergen County v. United StatesCourt of Appeals for the Third Circuit · 1969
19 more not listed; retrieve them via the Exa API.