Legal Opinion
Commissioner v. Rogers' Estate
Court of Appeals for the Second Circuit
Decided April 2, 1943No. 170PublishedCited by 4 opinions
1Opinion of the Court
FRANK, Circuit Judge.
This court disagrees with the Tax Court and agrees with the Commissioner. However, the several members of this court arrive at that conclusion by different paths. I shall, therefore, describe only my own path.
The taxpayer, purporting to rely on Helvering v. Grinnell, 294 U.S. 153, 55 S.Ct. 354, 79 L.Ed. 825, contends that, if there had been an exact equivalence between the interests appointed to the widow and daughter and the interests which those beneficiaries respectively would have received if the power had not been exercised, then those appointed interests would not…
2Cases cited11 opinions
- Helvering v. Safe Deposit & Trust Co. of BaltimoreSupreme Court of the United States · 1942
- Helvering v. GrinnellSupreme Court of the United States · 1935
- In Re the Appraisal, Under the Transfer Tax Act, of the Estate of LansingNew York Court of Appeals · 1905
- Legg's Estate v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1940
- Jackson ex dem. Eames v. PhippsNew York Supreme Court · 1815
6 more not listed; retrieve them via the Exa API.
3Cited by4 opinions
- Estate of Rogers v. CommissionerSupreme Court of the United States · 1943
- In re the Estate of RogersAppellate Division of the Supreme Court of the State of New York · 1945
- Lewis v. RothensiesCourt of Appeals for the Third Circuit · 1943
- Estate of Rogers v. CommissionerSupreme Court of the United States · 1943