Legal Opinion

Commissioner v. Central Nat. Bank of Cleveland

Court of Appeals for the Sixth Circuit

Decided May 8, 1941No. 8622PublishedCited by 15 opinions

1Opinion of the Court

MARTIN, Circuit Judge.

Before the Board of Tax Appeals, the Commissioner of Internal Revenue contended that the income for a portion of the year 1934 from four trusts, created by respondent’s decedent, W. G. Wilson, is taxable to the decedent’s estate under Section 166 of the Revenue Act of 1934,1 26 U.S.C.A. Int.Rev.Code, § 166. The Board held against the Commissioner, who, upon this petition for review, concedes that the income of the trusts is not taxable to the estate under Section 166, hut insists that the trust income is so taxable under Section 22(a) of the Revenue Act of 1934, C. 277,…

2Cases cited7 opinions

  1. Helvering v. CliffordSupreme Court of the United States · 1940
  2. Hormel v. HelveringSupreme Court of the United States · 1941
  3. Helvering v. HorstSupreme Court of the United States · 1940
  4. Harrison v. SchaffnerSupreme Court of the United States · 1941
  5. Helvering v. WoodSupreme Court of the United States · 1940

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3Cited by15 opinions

  1. Black Motor Co. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1942
  2. Commissioner of Internal Revenue v. WellsCourt of Appeals for the Sixth Circuit · 1942
  3. Central Nat. Bank v. Com'r of Internal RevenueCourt of Appeals for the Sixth Circuit · 1944
  4. Commissioner v. GoulderCourt of Appeals for the Sixth Circuit · 1941
  5. Charles A. Polizzi v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1957

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