Legal Opinion

Saulsbury v. United States

Court of Appeals for the Fifth Circuit

Decided November 10, 1952No. 13909_1PublishedCited by 52 opinions

1Opinion of the Court

HOLMES, Circuit Judge.

This is the question presented: Whether the net income of a trust, distributable currently to the beneficiary within the meaning of Section 162(b) of the Internal Revenue Code, 26 U.S.C.A. § 162(b), is income taxable to the beneficiary even though it was not actually received by her but was used by the trustee under an order of the state court to pay a loan, the proceeds of which were used to pay federal estate taxes on the corpus of the trust.

The taxpayer is the beneficiary of a trust established by her husband on June 19, 1932. The original trust agreement provided…

2Cases cited13 opinions

  1. Daine v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1948
  2. Baltzell v. MitchellCourt of Appeals for the First Circuit · 1925
  3. First-Mechanics Nat. Bank v. Commissioner of Int. Rev.Court of Appeals for the Third Circuit · 1940
  4. Doll v. CommissionerCourt of Appeals for the Eighth Circuit · 1945
  5. Loggie v. ThomasCourt of Appeals for the Fifth Circuit · 1945

8 more not listed; retrieve them via the Exa API.

3Cited by52 opinions

  1. Aerojet-General Corp. v. AskewCourt of Appeals for the Fifth Circuit · 1975
  2. Gallagher v. SmithCourt of Appeals for the Third Circuit · 1955
  3. First National Bank of Montgomery v. United StatesDistrict Court, M.D. Alabama · 1959
  4. Lois J. Newman (Formerly Lois J. Senderman) v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1955
  5. Brodrick v. GoreCourt of Appeals for the Tenth Circuit · 1955

47 more not listed; retrieve them via the Exa API.

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