Legal Opinion
Lincoln Electric Co. Employees' Profit-Sharing Trust v. Commissioner of Internal Revenue
Court of Appeals for the Sixth Circuit
Decided June 28, 1951No. 11211_1PublishedCited by 20 opinions
1Opinion of the Court
SIMONS, Circuit Judge.
The main question to be decided is whether the income of a profit-sharing trust established by the Lincoln Electric Company for its employees, is exempt from taxation under the provisions of Internal Revenue Code, § 165(a), 26 U.S.C.A. § 165 (a). An alternative issue is whether the trust indenture creates separate trusts, one for each employee. If the petitioner is right in its main contention, the second question need not be decided, and it is agreed that if the petitioner is right in either contention no tax is due.
The provisions, purpose and effect of the trust are…
2Cases cited5 opinions
- Manhattan General Equipment Co. v. Commissioner of Internal RevenueSupreme Court of the United States · 1936
- Burnet v. Chicago Portrait Co.Supreme Court of the United States · 1932
- Commissioner of Internal Revenue v. Lincoln Electric Co.Court of Appeals for the Sixth Circuit · 1949
- Tavannes Watch Co. v. Commissioner of Internal Rev.Court of Appeals for the Second Circuit · 1949
- Lincoln Electric Co. v. Commissioner of Internal Rev.Court of Appeals for the Sixth Circuit · 1947
3Cited by20 opinions
- United States v. General Shoe CorporationCourt of Appeals for the Sixth Circuit · 1960
- Mississippi River Fuel Corporation v. The United StatesUnited States Court of Claims · 1963
- Sherwood Swan & Co. v. CommissionerUnited States Tax Court · 1964
- McClintock-Trunkey Co. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1954
- American Broadcasting Co. v. United StatesDistrict Court, S.D. New York · 1953
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