Legal Opinion

Helvering v. Combs

Supreme Court of the United States

Decided December 16, 1935No. 238PublishedCited by 151 opinions

1Opinion of the CourtChief Justice Hughes

The trustees of E. E. Combs Well No. 2 contested the ruling of the Commissioner of Internal Revenue that the taxpayer was taxable as an association, and not as a trüst, on its income for the years 1925 and 1926. The Board of Tax Appeals sustained their contention and the Circuit Court of Appeals affirmed the order of the Board. 76 F. (2d) 682. A writ of certiorari was issued in view of the conflict of decisions to which we have referred in Morrissey v. Commissioner, ante, p. 344.

The trust was created “ to finance and drill a well for production and sale of oil and other hydro-carbon…

2Cases cited1 opinion

  1. Hecht v. MalleySupreme Court of the United States · 1924

3Cited by151 opinions

  1. A. A. Lewis & Co. v. CommissionerSupreme Court of the United States · 1937
  2. Estate of Craig M. Smith, Deceased, Ruth E. Smith v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1963
  3. United States v. Arthur R. Kintner and Alyce KintnerCourt of Appeals for the Ninth Circuit · 1954
  4. State Street Trust Co. v. HallMassachusetts Supreme Judicial Court · 1942
  5. Smith v. CommissionerUnited States Tax Court · 1959

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