Legal Opinion

Ruth Halle Rowen, Ethel F. Halle, and Edward Halle v. Commissioner of Internal Revenue

Court of Appeals for the Second Circuit

Decided September 9, 1954No. 22955-22957_1PublishedCited by 63 opinions

1Opinion of the Court

HINCKS, Circuit Judge.

This petition for review of a Tax Court decision, 18 T.C. 874, raises the question whether the receipt by named beneficiaries (the petitioners herein) of the proceeds of certain life insurance policies subjected them to liability enforceable against them as transferees under I.R.C. § 311, 26 U.S.C.A. § 311.

The facts of the case are as follows. Louis Halle of New York City, hereinafter referred to as the decedent, on and before January 20, 1930, took out four policies of life insurance upon his own life all of which were in force at the time of his death on January 4,…

2Cases cited19 opinions

  1. Phillips v. CommissionerSupreme Court of the United States · 1931
  2. Chase National Bank v. United StatesSupreme Court of the United States · 1929
  3. Central Bank of Washington v. HumeSupreme Court of the United States · 1888
  4. United States v. Joliet & Chicago RailroadSupreme Court of the United States · 1942
  5. Hatch v. Morosco Holding Co.Court of Appeals for the Second Circuit · 1931

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3Cited by63 opinions

  1. United States v. BessSupreme Court of the United States · 1958
  2. Commissioner v. SternSupreme Court of the United States · 1958
  3. Schuster v. CommissionerCourt of Appeals for the Ninth Circuit · 1962
  4. Kreps v. CommissionerUnited States Tax Court · 1964
  5. Diebold Foundation, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 2013

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