Legal Opinion

Guaranty Trust Co. v. Commissioner of Internal Revenue

Court of Appeals for the Second Circuit

Decided July 5, 1938No. 311PublishedCited by 19 opinions

1Opinion of the Court

AUGUSTUS N. HAND, Circuit Judge.

The Commissioner of Internal Revenue determined a deficiency in the estate tax of Jonathan Peterson, deceased, in the sum of $127,436.06 which was affirmed by the Board of Tax Appeals. The sole issue presented on the appeal to this court from the order of the Board is whether the Commissioner erred in refusing to allow as a deduction from the decedent’s gross estate an item of $1,048,000 evidenced by twelve promissory notes executed by the decedent and payable to Henrietta J. Peterson, Trustee. The petitioners, who are the executors of decedent’s will, contend…

2Cases cited6 opinions

  1. Utah Power & Light Co. v. United StatesSupreme Court of the United States · 1917
  2. Johnson v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1936
  3. Holmes v. . RoperNew York Court of Appeals · 1894
  4. Judson v. HatchAppellate Division of the Supreme Court of the State of New York · 1916
  5. In re the Transfer Tax upon the Estate of HendricksAppellate Division of the Supreme Court of the State of New York · 1914

1 more not listed; retrieve them via the Exa API.

3Cited by19 opinions

  1. Apt v. BirminghamDistrict Court, N.D. Iowa · 1950
  2. Goodwin's Estate v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1953
  3. Perrett v. CommissionerUnited States Tax Court · 1980
  4. Preston v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1942
  5. Peter E.C. Muserlian, Theodora Muserlian and Peter Muserlian v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1991

14 more not listed; retrieve them via the Exa API.

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API