Legal Opinion
Commissioner v. Guaranty Trust Co.
Court of Appeals for the Second Circuit
Decided August 4, 1944No. 5PublishedCited by 3 opinions
1Opinion of the Court
SWAN, Circuit Judge.
The question presented by these petitions is whether dividends declared before the death of an individual stockholder but pay-
able by the terms of the declaration to stockholders of record on dates which fell after his death, were income taxable to the decedent or to his estate.
The facts are not in dispute. Henry W. Putnam, a resident of New York, died on March 30, 1938, owning shares of stock in several corporations organized respectively under the laws of New Jersey, Delaware, Pennsylvania and Maine. Before his death each of the corporations declared a cash dividend…
2Cases cited7 opinions
- Lyeth v. HoeySupreme Court of the United States · 1938
- Helvering v. Estate of EnrightSupreme Court of the United States · 1941
- Helvering v. McGlue's EstateCourt of Appeals for the Fourth Circuit · 1941
- Tar Products Corporation v. Commissioner of Int. Rev.Court of Appeals for the Third Circuit · 1942
- Commissioner of Internal Revenue v. CohenCourt of Appeals for the Fifth Circuit · 1941
2 more not listed; retrieve them via the Exa API.
3Cited by3 opinions
- Estate of Putnam v. CommissionerSupreme Court of the United States · 1945
- O'Daniel's Estate v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1949
- Commissioner of Internal Rev. v. AMERICAN L. & T. CO.Court of Appeals for the Seventh Circuit · 1946