Legal Opinion
Commissioner of Internal Revenue v. Roosevelt & Son Inv. Fund
Court of Appeals for the Second Circuit
Decided May 3, 1937No. 273PublishedCited by 4 opinions
1Opinion of the Court
MANTON, Circuit Judge.
The partnership of Roosevelt & Son was originally formed in 1797. For years it has been dealing in investment securities. Its principal business has been to care for other people’s money, acting as trustee un*707der wills and deeds of trust, and serving as custodian. In order to render more efficient service, an Investment Fund was established. A form of trust was chosen to make the tax of each participant as nearly as possible identical with what he would have paid as individual owner of a proportionate share of the securities held by the respondent. Roosevelt & Son…
2Cases cited5 opinions
- Massachusetts Fire & Marine Ins. Co. v. Com'r of Int. Rev.Court of Appeals for the Second Circuit · 1930
- Hartford-Connecticut Trust Co. v. EatonCourt of Appeals for the Second Circuit · 1929
- Nash-Breyer Motor Co. v. BurnetSupreme Court of the United States · 1931
- Grain King Mfg. Co. v. CommissionerCourt of Appeals for the Second Circuit · 1931
- Roosevelt & Son Inv. Fund v. CommissionerUnited States Board of Tax Appeals · 1936
3Cited by4 opinions
- Germantown Trust Co. v. CommissionerSupreme Court of the United States · 1940
- Raulie v. United StatesCourt of Appeals for the Tenth Circuit · 1968
- Raulie v. United StatesCourt of Appeals for the Tenth Circuit · 1968
- United States v. National City Bank of New YorkDistrict Court, S.D. New York · 1937