Legal Opinion

Ellsworth M. Statler Trust v. Commissioner of Internal Revenue

Court of Appeals for the Second Circuit

Decided May 13, 1966No. Nos. 148-150, Dockets 29926-29928PublishedCited by 1 opinion

1Opinion of the Court

FRIENDLY, Circuit Judge:

This petition to review a decision of the Tax Court, 43 T.C. 208 (1964), on capital gains and deductions as applied to the income taxation of trusts, raises a novel question of the construction to be given the Internal Revenue Code of 1954.

In 1920 Ellsworth M. Statler executed an indenture conveying large amounts of stock of Hotels Statler Company, Inc., in trust for the benefit of his descendants. The indenture provided that separate trusts be established for each of Mr. Statler’s children, though in all significant aspects the trust estate was to be administered as a…

2Cases cited7 opinions

United States v. American Trucking AssociationsSupreme Court of the United States · 1940
Freuler v. HelveringSupreme Court of the United States · 1934
Helvering v. BlissSupreme Court of the United States · 1934
J. C. Penney Company, Transferee v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1962
Walter M. Weil and Adele D. Weil v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1956

2 more not listed; retrieve them via the Exa API.

3Cited by1 opinion

Ellsworth M. Statler Trust of January 1, 1920, for Ellsworth Morgan Statler, Frank C. Moore, Edwin F. Jaeckle and the Marine Trust Company of Western New York, Trustees v. Commissioner of Internal Revenue, Ellsworth M. Statler Trust of January 1, 1920, for Marian F. Statler, Ellsworth M. Statler Portion, Frank C. Moore, Edwin F. Jaeckle, and the Marine Trust Company of Western New York, Trustees v. Commissioner of Internal Revenue, Ellsworth M. Statler Trust of January 1, 1920, for Marian F. Statler, Milton Howland Statler Portion, Frank C. Moore, Edwin F. Jaeckle, and the Marine Trust Company of Western New York, Trustees v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1966