Legal Opinion
Raymond J. Funkhouser's Trusts v. Commissioner of Internal Revenue
Court of Appeals for the Fourth Circuit
Decided January 14, 1960No. 7922PublishedCited by 9 opinions
1Opinion of the Court
R. DORSEY WATKINS, District Judge:
Question Presented
The Commissioner of Internal Revenue (Respondent) held that under the terms of certain trusts created by Raymond J. Funkhouser (hereinafter, Petitioner) $3,000 exclusions were not allowable under the Internal Revenue Code of 1939, 26 U.S.C. § 1003, for each gift to such trusts by Petitioner in the years 1948, 1950, 1951, 1952 and 1953. The Tax Court affirmed. 1 We agree with the result reached by the Tax Court.
Position of the Parties
Petitioner over the years 1948, 1950, 1951 and 1953 established seventeen separate trusts for his five…
2Cases cited9 opinions
- Commissioner v. DisstonSupreme Court of the United States · 1945
- Commissioner of Internal Revenue v. MaresiCourt of Appeals for the Second Circuit · 1946
- Fisher v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1942
- Evans v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1952
- Kniep v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1949
4 more not listed; retrieve them via the Exa API.
3Cited by9 opinions
- George Fischer v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1961
- Lera H. Stark v. United States of America, William P. Stark v. United StatesCourt of Appeals for the Eighth Circuit · 1973
- Rosen v. CommissionerUnited States Tax Court · 1967
- Rosen v. CommissionerCourt of Appeals for the Fourth Circuit · 1968
- Mercantile-Safe Deposit and Trust Co. v. United StatesDistrict Court, D. Maryland · 1970
4 more not listed; retrieve them via the Exa API.