Ittleson v. Anderson

KNOX, District Judge.

' This is an action to recover $5[075, the amount paid by plaintiffs as federal capital stock tax for the tax years ending June 30, 1921, to June 30, 1926, both inclusive. The question to be decided, upon cross-motions for a directed verdict, is whether plaintiffs, as trustees of the Ittleson Investment Trust, are subject to capital stock taxes. This, in turn, depends upon whether the Ittleson Investment Trust, which is of the Massachusetts variety was an “association” which was “doing business” within the meaning of sections 2 and 1000 of the Revenue Act of 1921 (42…