Legal Opinion

Loeb v. COMMISSIONER OF INTERNAL REVENUE

Court of Appeals for the Seventh Circuit

Decided December 20, 1946No. 9082, 9083PublishedCited by 12 opinions

1Opinion of the Court

EVANS, Circuit Judge.

The Commissioner has imposed deficiency income taxes upon Herbert Loeb for the years 1939 and 1940, which the Tax Court has sustained in the amounts of $7,159.18 and $20,785.16, respectively.

The alleged deficiency grows out of the Commissioner’s assertion that Loeb was taxable on $60,000 dividends, declared in the years in question, 1 upon ten thousand shares of Hillman Company stock, which Loeb had transferred, December 15, 1939, to two trusts, for the benefit respectively of his two adult sons. The transfer of this stock in trust was subject to a pre-existing contract…

2Cases cited2 opinions

  1. Helvering v. StuartSupreme Court of the United States · 1942
  2. Stuart v. CommissionerCourt of Appeals for the Seventh Circuit · 1941

3Cited by12 opinions

  1. Furman v. CommissionerUnited States Tax Court · 1966
  2. Commissioner v. MakranskyCourt of Appeals for the Third Circuit · 1963
  3. Sheaffer v. CommissionerUnited States Tax Court · 1961
  4. Commissioner of Internal Revenue, in No. 13,785 v. Robert Makransky, of the Estate of Harry Makransky, and Helen Makransky. Commissioner of Internal Revenue, in Nos. 13,786, 13,787 v. Emanuel Moss and Sylvia Moss. Commissioner of Internal Revenue, in Nos. 13,788, 13,789 v. Hilda B. Schneider. Trust Under Deed of Joseph Binenstock (Deceased), Girard Trust Corn Exchange Bank, Theodora B. Jacobs, Sylvia B. Moss, Hilda B. Schneider (Formerly Hilda B. Raines), Helen B. Makransky, John Tait and Albert Barnes Zink, Trustees, in Nos. 13,790, 13,791 v. Commissioner of Internal Revenue, Commissioner of Internal Revenue, in Nos. 13,792, 13,793 v. Allen C. Jacobs and Theodora B. JacobsCourt of Appeals for the Third Circuit · 1963
  5. Estate Of Craig R. SheafferCourt of Appeals for the Eighth Circuit · 1963

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