Legal Opinion
Commissioner of Internal Revenue v. PHILLIPS'ESTATE
Court of Appeals for the Fifth Circuit
Decided March 20, 1942No. 9977PublishedCited by 13 opinions
1Opinion of the Court
McCORD, Circuit Judge.
The petition for review involves gift tax for the year 1936. The facts were stipulated, and the sole question presented below was whether under § 504(b) of the Revenue Act of 1932, 47 Stat. 169, 247, 26 U.S.C.A. Int.Rev.Acts, page 585, the donor of property in trust for the benefit of thirteen beneficiaries was entitled to a single gift tax exclusion of $5,000, or to thirteen separate exclusions not exceeding $5,000 each. The Board held that the beneficiaries were the donees of the gifts, and that in determining the donor’s gift tax liability he should be allowed an…
2Cases cited9 opinions
- Hormel v. HelveringSupreme Court of the United States · 1941
- United States v. PelzerSupreme Court of the United States · 1941
- Helvering v. HutchingsSupreme Court of the United States · 1941
- Ryerson v. United StatesSupreme Court of the United States · 1941
- Helvering v. RichterSupreme Court of the United States · 1941
4 more not listed; retrieve them via the Exa API.
3Cited by13 opinions
- Fondren v. CommissionerSupreme Court of the United States · 1945
- Thorrez v. CommissionerUnited States Tax Court · 1958
- Welch v. PaineCourt of Appeals for the First Circuit · 1942
- Nell K. Ross, Individually and James G. Harris and Elizabeth Ross Harris, Independent of the Estate of James H. Ross, Deceased v. United StatesCourt of Appeals for the Fifth Circuit · 1965
- Commissioner of Internal Revenue v. KempnerCourt of Appeals for the Fifth Circuit · 1942
8 more not listed; retrieve them via the Exa API.