Legal Opinion
Rosenthal v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided June 24, 1953No. 127, Docket 22463PublishedCited by 48 opinions
1Opinion of the Court
CLARK, Circuit judge.
The taxpayer, Paul Rosenthal, petitions for review of a decision of Judge Disney in the Tax Court, reviewed by the entire court, 17 T.C. 1047, in so far as it determines a deficiency of $16,983.17 in his gift tax for 1946 and rejects his claim of overpayment of that tax in the amount of $160,-212. In the same decision the court found a deficiency of $23,194.37 in Rosenthal’s gift tax for 1944, but neither party has petitioned for review of this portion of the decision. At issue here is the taxability of certain obligations undertaken by Rosen-thal toward his children in…
2Cases cited29 opinions
- Penfield Co. v. Securities & Exchange CommissionSupreme Court of the United States · 1947
- Helvering v. RankinSupreme Court of the United States · 1935
- Commissioner v. WemyssSupreme Court of the United States · 1945
- Arrowsmith v. CommissionerSupreme Court of the United States · 1952
- LeTulle v. ScofieldSupreme Court of the United States · 1940
24 more not listed; retrieve them via the Exa API.
3Cited by48 opinions
- Phoenix Coal Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1956
- Glen v. CommissionerUnited States Tax Court · 1966
- United States v. Howard Past, of the Estate of Edna C. Rosedale Ogg, DeceasedCourt of Appeals for the Ninth Circuit · 1965
- McDonald v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1954
- Babcock & Wilcox Co. v. Pedrick. Babcock & Wilcox Tube Co. v. PedrickCourt of Appeals for the Second Circuit · 1954
43 more not listed; retrieve them via the Exa API.