Legal Opinion
United States v. Brown
Court of Appeals for the Ninth Circuit
Decided February 12, 1943No. 10185PublishedCited by 12 opinions
1Opinion of the Court
HEALY, Circuit Judge.
The appeal is from a judgment awarding refund of estate taxes paid under protest. The question presented is whether, under the provisions of § 302(c) of the Revenue Act of 1926, 26 U.S.C.A. Int.Rev.Acts, page 227, all or any por/ion of the value of the corpus of an irrevocable trust was includible in the gross estate of the trustor.
The taxpayers are the executors of the last will of Frederick L. Brown who died in 1934 at the age of 67. In 1923 Brown 1 created an irrevocable trust whereby he transferred to himself and his two sons, as trustees, certain shares of stock then…
2Cases cited5 opinions
- Helvering v. HallockSupreme Court of the United States · 1940
- Reinecke v. Northern Trust Co.Supreme Court of the United States · 1929
- Hassett v. WelchSupreme Court of the United States · 1938
- May v. HeinerSupreme Court of the United States · 1930
- Commissioner of Internal Revenue v. KelloggCourt of Appeals for the Third Circuit · 1941
3Cited by12 opinions
- Helvering v. ProctorCourt of Appeals for the Second Circuit · 1944
- United States v. GallagherCourt of Appeals for the Ninth Circuit · 1945
- Judith Badgley v. United StatesCourt of Appeals for the Ninth Circuit · 2020
- Fifth Ave. Bank of New York v. NunanDistrict Court, E.D. New York · 1945
- Commissioner v. Lasker's EstateCourt of Appeals for the Seventh Circuit · 1944
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