Legal Opinion
Estate of Smith v. Commissioner
Court of Appeals for the Third Circuit
Decided June 30, 1961No. Nos. 13466, 13467PublishedCited by 9 opinions
1Opinion of the Court
HASTIE, Circuit Judge.
On April 17, 1953, the directors of a personal holding company, a New Jersey corporation, declared a dividend to be paid on May 10, 1953, to the stockholders *479then of record. On May 9, 1953, the principal stockholders gave certain shares of their stock to their several children. Thereafter, the May 10th distribution of dividends on those shares was made to the children, who reported the amounts thus received as their income. However, in the present proceeding the Commissioner has assessed deficiencies against the parents, treating the dividend payments to the children as…
2Cases cited7 opinions
- Helvering v. HorstSupreme Court of the United States · 1940
- Estate of Putnam v. CommissionerSupreme Court of the United States · 1945
- Martindell v. Fiduciary Counsel, Inc.Supreme Court of New Jersey · 1943
- Holmes v. CommissionerUnited States Tax Court · 1943
- Tar Products Corporation v. Commissioner of Int. Rev.Court of Appeals for the Third Circuit · 1942
2 more not listed; retrieve them via the Exa API.
3Cited by9 opinions
- Silco, Inc. v. United StatesCourt of Appeals for the Fifth Circuit · 1986
- Caruth Corporation, W.W. And Mable P. Caruth v. United StatesCourt of Appeals for the Fifth Circuit · 1989
- Chase Manhattan Bank v. BurdenDistrict of Columbia Court of Appeals · 1985
- Wallace v. United StatesDistrict Court, S.D. Iowa · 1970
- Caruth v. United StatesDistrict Court, N.D. Texas · 1987
4 more not listed; retrieve them via the Exa API.