Legal Opinion
Commissioner of Internal Revenue v. Marshall
Court of Appeals for the Second Circuit
Decided February 3, 1942No. 171PublishedCited by 57 opinions
1Opinion of the Court
FRANK, Circuit Judge.
This is an appeal, by petition for review filed by the Commissioner of Internal Revenue, from a decision of the Board of Tax Appeals, holding that the value of certain remainders created by trusts executed by the respondent was not subject to gift tax for the year 1937. The facts found by the Board may be summarized as follows:
The taxpayer (respondent) established two irrevocable trusts on June 3, 1937, and transferred $10,000 to each. The income of one was to be paid to Kathleen Bowen for life, and the income of the other was to be paid to Mary Eells for life. The…
2Cases cited25 opinions
- Cohens v. VirginiaSupreme Court of the United States · 1821
- Helvering v. HallockSupreme Court of the United States · 1940
- Myers v. United StatesSupreme Court of the United States · 1926
- Ithaca Trust Co. v. United StatesSupreme Court of the United States · 1929
- Humphrey's v. United StatesSupreme Court of the United States · 1935
20 more not listed; retrieve them via the Exa API.
3Cited by57 opinions
- Messing v. CommissionerUnited States Tax Court · 1967
- Smith v. ShaughnessySupreme Court of the United States · 1943
- Symington v. CommissionerUnited States Tax Court · 1986
- Westchester County Park Commission v. United StatesCourt of Appeals for the Second Circuit · 1944
- Commissioner of Internal Revenue v. Beck's EstateCourt of Appeals for the Second Circuit · 1942
52 more not listed; retrieve them via the Exa API.