Legal Opinion
Gloria M. Packard Polt, Estate of Robert L. Dula, Deceased v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided May 25, 1956No. 227, Docket 23773PublishedCited by 13 opinions
1Opinion of the Court
CLARK, Chief Judge.
This is a petition for review of a decision by Judge Tietjens of the Tax Court of the United States, 23 T.C. 646, hold-1 ing that the proportionate share of certain mortgage-salvage proceeds represented by bonds and mortgages allocated by a trustee in 1945 to the beneficiary •of a trust was taxable to the beneficiary at that time, and not later in 1947, after the beneficiary’s death and the entry of a Surrogate’s decree settling the trustee’s account and ordering distribution ■of the proceeds. We shall proceed to summarize the facts of the transaction now in issue, which…
2Cases cited17 opinions
- Freuler v. HelveringSupreme Court of the United States · 1934
- Plunkett v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1941
- In Re the Will of ChapalNew York Court of Appeals · 1936
- In Re the Accounting of Bankers Trust Company, as Trustee Under the Will of OtisNew York Court of Appeals · 1937
- In Re the Accounting of Bank of New YorkNew York Court of Appeals · 1945
12 more not listed; retrieve them via the Exa API.
3Cited by13 opinions
- Estate of Petschek v. CommissionerUnited States Tax Court · 1983
- Kennecott Copper Corporation v. The United StatesUnited States Court of Claims · 1965
- Kearney v. A'HearnDistrict Court, S.D. New York · 1962
- Phillips v. CommissionerUnited States Tax Court · 1996
- BANK OF AMERICA NATIONAL TRUST AND SAVINGS ASSOCIATION v. United StatesDistrict Court, N.D. California · 1962
8 more not listed; retrieve them via the Exa API.