Legal Opinion
Loggie v. Thomas
Court of Appeals for the Fifth Circuit
Decided December 10, 1945No. 11449PublishedCited by 20 opinions
1Opinion of the Court
WALLER, Circuit Judge.
The chief question involved in this case is whether or not a declaratory judgment of a state court, rendered after a federal income tax liability had accrued, in a case in which neither the Collector nor the Commissioner of Internal Revenue was a party, is res judicata in a suit in the Federal Court involving such income tax liability.
The income tax consequences to donors or to trustees are not always controlled by the sole incidence of the naked legal title. See Helvering, Commissioner, v. Clifford, 309 U.S. 331, 60 S.Ct. 554, 84 L.Ed. 788; Helvering, Commissioner, v.…
2Cases cited5 opinions
- Helvering v. CliffordSupreme Court of the United States · 1940
- Helvering v. HorstSupreme Court of the United States · 1940
- Harrison v. SchaffnerSupreme Court of the United States · 1941
- DuPont v. CommissionerSupreme Court of the United States · 1933
- Sewell v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1945
3Cited by20 opinions
- Daine v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1948
- Gallagher v. SmithCourt of Appeals for the Third Circuit · 1955
- Saulsbury v. United StatesCourt of Appeals for the Fifth Circuit · 1952
- Estate of Nicholson v. CommissionerUnited States Tax Court · 1990
- Sinopoulo v. JonesCourt of Appeals for the Tenth Circuit · 1946
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