Legal Opinion
Tyrrell v. Commissioner of Internal Revenue
Court of Appeals for the Fifth Circuit
Decided July 9, 1937No. 8439PublishedCited by 5 opinions
1Opinion of the Court
HUTCHESON, Circuit Judge.
Petitioners, citizens of Texas, were until 1927 members of the W. C. Tyrrell Trust, “a joint stock association without individual liability to shareholders.” In that year they completely dissolved it, and distributed its assets to the associates.
The Commissioner, applying section 201 (c) of the Revenue Act of 1926 1 to petitioners’ income tax returns, determined deficiencies accordingly. The Board of Tax Appeals affirmed 34 B.T. 707.
Petitioners make two points against the Board’s order. They urge, rather faintly, that viewed generally, the section must be regarded as…
2Cases cited8 opinions
- Burnet v. HarmelSupreme Court of the United States · 1932
- Morrissey v. CommissionerSupreme Court of the United States · 1935
- Burk-Waggoner Oil Assn. v. HopkinsSupreme Court of the United States · 1925
- Herring v. CommissionerSupreme Court of the United States · 1934
- Thompson v. SchmittTexas Supreme Court · 1925
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3Cited by5 opinions
- United States v. Arthur R. Kintner and Alyce KintnerCourt of Appeals for the Ninth Circuit · 1954
- Sherman v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1944
- Cornwall v. CommissionerUnited States Tax Court · 1967
- Estate of Philip Landau, Deceased, Herbert Landau and Sidney Landau, Executors v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1955
- Cornwall v. CommissionerUnited States Tax Court · 1967