Legal Opinion
Smith v. Manning (Two Cases)
Court of Appeals for the Third Circuit
Decided May 28, 1951No. 10338PublishedCited by 19 opinions
1Opinion of the Court
KALODNER, Circuit Judge.
The question presented is whether sums of money received by the plaintiffs in the taxable years 1940 and 1941 were income, subject to income taxes, or gifts, exempt therefrom. 1 The plaintiffs had filed claims for refund of income taxes erroneously paid, and upon rejection of the claims by the Commissioner of Internal Revenue, brought the instant actions against the local Collector. The Court below determined that the amounts involved were gifts, and gave judgment accordingly. 91 F.Supp. 812. The Collector has taken this appeal.
The plaintiffs are sisters, Irma and Aida…
2Cases cited20 opinions
- United States v. United States Gypsum Co.Supreme Court of the United States · 1948
- Helvering v. CliffordSupreme Court of the United States · 1940
- Old Colony Trust Co. v. CommissionerSupreme Court of the United States · 1929
- Bogardus v. CommissionerSupreme Court of the United States · 1937
- Commissioner v. JacobsonSupreme Court of the United States · 1949
15 more not listed; retrieve them via the Exa API.
3Cited by19 opinions
- Sanabria v. Sucn. de González MartinezSupreme Court of Puerto Rico · 1961
- United States v. BurdickCourt of Appeals for the Third Circuit · 1954
- Edward F. Webber v. Commissioner or Internal Revenue, Edward F. Webber and Lelia Vesta Webber v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1955
- Edward S. Canton v. United StatesCourt of Appeals for the Eighth Circuit · 1955
- Flax v. Tesorero de Puerto RicoSupreme Court of Puerto Rico · 1954
14 more not listed; retrieve them via the Exa API.