Legal Opinion
Commissioner of Internal Revenue v. Prouty
Court of Appeals for the First Circuit
Decided November 1, 1940No. 3603PublishedCited by 41 opinions
1Opinion of the Court
MAGRUDER, Circuit Judge.
In 1923 Olive H. Prouty, the taxpayer herein, set up three trusts. Between 1923 ancl 1931 the grantor, by virtue of power reserved to her, made various amendments to the trust instruments. The Commissioner ruled that the gifts were not complete in 1931; that under Section 501 of the Revenue Acl of 1932, 47 Stat. 245, as amended by Section 511 of the Revenue Act of 1934, 48 Stat. 758, 26 U.S.C.A. Int.Rev. Acts, pages 580, 769, gift taxes became due upon amendment of each of the trusts on January 2, 1935, whereby the grantor finally relinquished all reserved power to…
2Cases cited13 opinions
- Helvering v. CliffordSupreme Court of the United States · 1940
- Estate of Sanford v. CommissionerSupreme Court of the United States · 1939
- Burnet v. GuggenheimSupreme Court of the United States · 1933
- Curry v. McCanlessSupreme Court of the United States · 1939
- Helvering v. City Bank Farmers Trust Co.Supreme Court of the United States · 1935
8 more not listed; retrieve them via the Exa API.
3Cited by41 opinions
- Merrill v. FahsSupreme Court of the United States · 1945
- Smith v. ShaughnessySupreme Court of the United States · 1943
- Commissioner of Internal Revenue v. Beck's EstateCourt of Appeals for the Second Circuit · 1942
- Commissioner of Internal Revenue v. MarshallCourt of Appeals for the Second Circuit · 1942
- Flood v. United StatesCourt of Appeals for the First Circuit · 1943
36 more not listed; retrieve them via the Exa API.