Legal Opinion
Lovering v. United States
District Court, D. Massachusetts
Decided March 11, 1943No. 1884PublishedCited by 4 opinions
1Opinion of the Court
SWEENEY, District Judge.
This is a decision on a motion for summary judgment. The facts are not in dispute, and this decision is based upon a conclusion whether this taxpayer is a “related taxpayer” within the meaning of Section 3801 of the Internal Revenue Code, 26 U. S.C.A. Int.Rev.Code, § 3801.
The plaintiff is the sole beneficiary of a trust established under the will of Frederick R. Sears. The res of the trust consists entirely of shares in a Massachusetts trust called the F. R. Sears Real Estate Trust, hereinafter referred to as the Trust. In reporting her income for the years 1935 and…
2Cases cited2 opinions
- Sears v. HassettCourt of Appeals for the First Circuit · 1940
- Sears v. HassettDistrict Court, D. Massachusetts · 1940
3Cited by4 opinions
- Taylor v. CommissionerUnited States Tax Court · 1956
- Olaf E. Taxeraas, Administrator of the Estate of Carl Taxeraas and Irene Taxeraas v. United StatesCourt of Appeals for the Eighth Circuit · 1959
- Barret v. United StatesDistrict Court, W.D. Louisiana · 1952
- Taylor v. CommissionerUnited States Tax Court · 1956