Legal Opinion

Estate of Schneider v. Comm'r

United States Tax Court

Decided February 25, 1958No. Docket Nos. 54289, 54290, 54291, 54292, 54293, 54294, 54295, 54296Published

1. Held, the returns of Harry Schneider were false and fraudulent and a part of each deficiency was due to fraud with intent to evade tax for each of the years 1944 through 1950. 2. Held, beneficiaries of various "Totten trusts" are liable as transferees, to the extent of trust assets individually received, for deficiencies and additions to tax determined against decedent for years 1944 through 1950. 3. Held, transferees of assets of decedent are liable to the extent of…

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1. Held, the returns of Harry Schneider were false and fraudulent and a part of each deficiency was due to fraud with intent to evade tax for each of the years 1944 through 1950. 2. Held, beneficiaries of various "Totten trusts" are liable as transferees, to the extent of trust assets individually received, for deficiencies and additions to tax determined against decedent for years 1944 through 1950. 3. Held, transferees of assets of decedent are liable to the extent of assets received for deficiencies and additions to tax determined against decedent for years 1944 through 1950.

1Opinion of the Court

Estate of Harry Schneider, Deceased, Molly Schneider, Administratrix, and Molly Schneider, et al., 1 Petitioners, v. Commissioner of Internal Revenue, Respondent 2

Estate of Schneider v. Comm'r

Docket Nos. 54289, 54290, 54291, 54292, 54293, 54294, 54295, 54296

United States Tax Court

29 T.C. 940; 1958 U.S. Tax Ct. LEXIS 251;

February 25, 1958, Filed

Decisions in Docket Nos. 54289, 54292, 54294, 54295, 54296 will be entered under Rule 50.

1. Held, the returns of Harry Schneider were false and fraudulent and a part of each deficiency was due to fraud with intent to evade tax for each of the years 1944…

2Cases cited9 opinions

  1. Holland v. United StatesSupreme Court of the United States · 1955
  2. Helvering v. CliffordSupreme Court of the United States · 1940
  3. In Re the Accounting of TottenNew York Court of Appeals · 1904
  4. Tauber v. CommissionerUnited States Tax Court · 1955
  5. Papineau v. CommissionerUnited States Tax Court · 1957

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