Legal Opinion
Bell's Estate v. Commissioner of Internal Revenue
Court of Appeals for the Eighth Circuit
Decided August 4, 1943No. 12484, 12485PublishedCited by 38 opinions
1Opinion of the Court
SANBORN, Circuit Judge.
The question for decision is whether, under the Revenue Act of 1936, the consideration received by the life beneficiary of a trust for the transfer of the life interest to the remainderman was ordinary income or was capital.
The facts are agreed to and are as stated in the opinion of the Board of Tax Appeals (now the Tax Court of the United States), 46 B.T.A. 484. It is unnecessary to restate them in detail.
Frederic Somers Bell (now deceased) and Frances Laird Bell, husband and wife, of Winona, Minnesota, on April 28, 1932, each created a trust. The corpus of each trust…
2Cases cited28 opinions
- Hormel v. HelveringSupreme Court of the United States · 1941
- Helvering v. HorstSupreme Court of the United States · 1940
- Blair v. CommissionerSupreme Court of the United States · 1937
- Helvering v. StuartSupreme Court of the United States · 1942
- Harrison v. SchaffnerSupreme Court of the United States · 1941
23 more not listed; retrieve them via the Exa API.
3Cited by38 opinions
- Commissioner of Internal Revenue v. Golonsky. Commissioner of Internal Revenue v. GoldCourt of Appeals for the Third Circuit · 1952
- Commissioner of Internal Revenue v. RayCourt of Appeals for the Fifth Circuit · 1954
- Commissioner of Internal Revenue v. McCue Bros. & Drummond, IncCourt of Appeals for the Second Circuit · 1954
- McAllister v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1946
- Cuddihy v. CommissionerUnited States Tax Court · 1959
33 more not listed; retrieve them via the Exa API.