Legal Opinion
Helvering v. Evans
Court of Appeals for the Third Circuit
Decided March 2, 1942No. 7731, 7732PublishedCited by 17 opinions
1Opinion of the Court
GOODRICH, Circuit Judge.
These two cases involve the same question. The asserted liability of each taxpayer arises out of the same transaction and the sole difference is that, if the Commissioner’s position is upheld, one is liable for a deficiency for one year only, the other for three years.
The liability asserted is claimed under Section 166 1 and 167 2 of the Revenue Acts of 1934 and 1936 for income accumulated in the respective trusts. The Commissioner also argues for the applicability of Section 22(a), 26 U.S.C.A. Int.Rev. Code, § 22(a).
The essential facts are not in dispute. A testator…
2Cases cited7 opinions
- White v. HigginsCourt of Appeals for the First Circuit · 1940
- Kent v. RothensiesCourt of Appeals for the Third Circuit · 1941
- Rollins v. HelveringCourt of Appeals for the Eighth Circuit · 1937
- Kaplan v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1933
- Morton v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1940
2 more not listed; retrieve them via the Exa API.
3Cited by17 opinions
- Newton Trust Co. v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1947
- Commissioner v. MakranskyCourt of Appeals for the Third Circuit · 1963
- Strite v. McGinnesCourt of Appeals for the Third Circuit · 1964
- Athanasius Y. Samuel v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1962
- Archbishop Samuel Trust v. CommissionerUnited States Tax Court · 1961
12 more not listed; retrieve them via the Exa API.