Legal Opinion
Frank v. Commissioner
Court of Appeals for the Third Circuit
Decided November 2, 1944No. 8645PublishedCited by 2 opinions
1Opinion of the Court
GOODRICH, Circuit Judge.
This case is part of the same litigation as that involved in Nos. 8644 and 8646. 145 F.2d 411. It concerns the income for 1939 of Cecelia K. Frank one of the beneficiaries and also one of the trustees of the Robert J. Frank Trust
Under the terms of the trust the taxpayer was to receive- 50% of the net income of the trust. With her consent, however, the trustees could choose charitable organizations to participate in the income or principal of the trust. There was a further provision that no title in the trust estate or the income therefrom should vest in the…
2Cases cited7 opinions
- Helvering v. HorstSupreme Court of the United States · 1940
- Harrison v. SchaffnerSupreme Court of the United States · 1941
- Helvering v. EubankSupreme Court of the United States · 1941
- Helvering v. FitchSupreme Court of the United States · 1940
- Commissioner of Internal Revenue v. GianniniCourt of Appeals for the Ninth Circuit · 1942
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3Cited by2 opinions
- Grant v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1949
- Emery v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1946