Chicago Title & Trust Co. v. Smietanka
District Court, N.D. Illinois
At Law. Action by the Chicago Title & Trust Company, as trustee of the Chicago City & Connecting Railways Collateral Trust, against one Smietanka, Collector of Internal Revenue. On demurrer to declaration.
1Opinion of the Court
PAGE, Circuit Judge.
Persons owning capital stock of five street railways in Chicago, desiring to effect a unitary control of the properties, executed the agreement out of which grows the question here, viz.: Did that agreement create a joint-stock company or association, taxable under section II G (a) of the federal Revenue Act of 1913 (38 Stat. 172) ? Such a tax was paid by the plaintiff under protest, and it brings this (and four similar suits) against the defendant, a former internal revenue collector, to recover the money paid on the ground that it was an illegal tax. The question arises…
2Cases cited2 opinions
- Crocker v. MalleySupreme Court of the United States · 1919
- Eliot v. FreemanSupreme Court of the United States · 1911
3Cited by10 opinions
- Hecht v. MalleySupreme Court of the United States · 1924
- Hecht v. MalleySupreme Court of the United States · 1924
- Wilson & Co. v. United Packinghouse Wkrs. of AmericaDistrict Court, N.D. Iowa · 1960
- Bouchard v. First People's TrustMassachusetts Supreme Judicial Court · 1925
- Malley v. HowardCourt of Appeals for the First Circuit · 1922
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