Legal Opinion
Boyle v. United States
Court of Appeals for the Third Circuit
Decided December 29, 1965No. 15118PublishedCited by 26 opinions
1Opinion of the Court
MeLAUGHLIN, Circuit Judge.
Briefly stated, the problem involved is whether or not appellant taxpayers are within the purview of 26 U.S.C. § 691, so as to be entitled to a deduction for estate taxes paid on certain accumulated dividend arrearages which are being declared and paid to taxpayers causing them to become liable for income taxes thereon; or in the alternative does the doctrine of Equitable Recoupment, as set forth in Bull v. United States, 295 U.S. 247, 55 S.Ct. 695, 79 L.Ed. 1421 (1935) apply to this particular situation.
John F. Boyle died on December 8, 1953, leaving his entire…
2Cases cited8 opinions
- Bull v. United StatesSupreme Court of the United States · 1935
- Stone v. WhiteSupreme Court of the United States · 1937
- Rothensies v. Electric Storage Battery Co.Supreme Court of the United States · 1946
- First Nat. Bank of Boston v. MaineSupreme Court of the United States · 1932
- Klein v. Board of Tax Supervisors of Jefferson Cty.Supreme Court of the United States · 1930
3 more not listed; retrieve them via the Exa API.
3Cited by26 opinions
- Continental Equities, Inc., Cross-Appellant v. Commissioner of Internal Revenue, Cross-AppelleeCourt of Appeals for the Fifth Circuit · 1977
- Estate of Frank Branson, Deceased Mary M. March v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 2001
- Michael G. O'Brien v. United StatesCourt of Appeals for the Seventh Circuit · 1985
- Estate of Mueller v. Comm'rUnited States Tax Court · 1993
- Estate of Branson v. CommissionerUnited States Tax Court · 1999
21 more not listed; retrieve them via the Exa API.