Legal Opinion
Hutchings-Sealy Nat. Bank v. Commissioner
Court of Appeals for the Fifth Circuit
Decided March 7, 1944No. 10757PublishedCited by 11 opinions
1Opinion of the Court
SIBLEY, Circuit Judge.
Mary M. Hutchings in 1935 by deed made an irrevocable conveyance of property to two of her sons for the benefit of themselves and five other of her children, all adults. In settling the gift taxes the Commissioner allowed only one exclusion of $5,000, holding the trust to be the single donee. This court reversed, holding there were seven donees and there should be seven exclusions. Hutchings v. Commissioner, 5 Cir., 111 F.2d 229. The Supreme Court affirmed, but without prejudice to a consideration by the Board of Tax Appeals of the question whether the gifts were not of…
2Cases cited9 opinions
- Old Colony Trust Co. v. CommissionerSupreme Court of the United States · 1929
- United States v. PelzerSupreme Court of the United States · 1941
- Helvering v. HutchingsSupreme Court of the United States · 1941
- Ryerson v. United StatesSupreme Court of the United States · 1941
- Miller v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1939
4 more not listed; retrieve them via the Exa API.
3Cited by11 opinions
- Fondren v. CommissionerSupreme Court of the United States · 1945
- West v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1945
- Lincoln Electric Co. v. Commissioner of Internal Rev.Court of Appeals for the Sixth Circuit · 1947
- Wood v. CommissionerUnited States Tax Court · 1951
- Blasdel v. CommissionerUnited States Tax Court · 1972
6 more not listed; retrieve them via the Exa API.