Legal Opinion
Duffy v. United States
District Court, S.D. Ohio
Decided April 12, 1972No. 6946PublishedCited by 4 opinions
1Opinion of the Court
OPINION AND ORDER
PORTER, District Judge.
This is a tax refund case involving a Clifford trust (one with a lease-back). Two questions are presented. One, under the facts stipulated, did the taxpayer-lessee properly claim the rent as a deduction? Two, is the income of the trust taxable to the grantors?
Taxpayers purchased the land and building at 155 West McMillan Street, Cincinnati, Ohio, on July 31, 1962. On February 26, 1963, they executed a trust agreement, a copy of which is set out in the appendix. The trust agreement was with The Provident Bank and conveyed the property to the trustee in…
2Cases cited8 opinions
- Helvering v. CliffordSupreme Court of the United States · 1940
- Skemp v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1948
- Brown v. Commissioner of Internal Revenue (Two Cases)Court of Appeals for the Third Circuit · 1950
- Oakes v. Comm'rUnited States Tax Court · 1965
- Felix v. CommissionerUnited States Tax Court · 1954
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3Cited by4 opinions
- F. Paul Duffy and Virginia H. Duffy v. United StatesCourt of Appeals for the Sixth Circuit · 1973
- Perry v. United StatesDistrict Court, E.D. North Carolina · 1974
- Bank of New York Mellon v. Christopher Communities at Southern Highlands Golf Club HomeDistrict Court, D. Nevada · 2019
- Power Integrations, Inc. v. Silanna Semiconductor North America, Inc.District Court, S.D. California · 2020