Legal Opinion

Suhr v. Commissioner

Court of Appeals for the Sixth Circuit

Decided March 5, 1942No. Nos. 8785, 8786PublishedCited by 20 opinions

1Opinion of the Court

SIMONS, Circuit Judge.

The petitions assail decisions of the Board of Tax Appeals sustaining determinations of the respondent, that the income of an irrevocable trust created for the benefit of the petitioner’s wife and stepsons, is taxable to the grantor. While other grounds in support of the assessment were urged, the Board’s decision, two members dissenting, was based solely upon the doctrine of Douglas v. Willcuts, 296 U.S. 1, 56 S.Ct. 59, 80 L.Ed. 3, 101 A. L.R. 391, the Board holding that because the trust instrument gave to the trustee a conditional right to invade the corpus of the…

2Cases cited20 opinions

  1. Helvering v. CliffordSupreme Court of the United States · 1940
  2. Hormel v. HelveringSupreme Court of the United States · 1941
  3. Helvering v. HorstSupreme Court of the United States · 1940
  4. Douglas v. WillcutsSupreme Court of the United States · 1935
  5. Helvering v. EubankSupreme Court of the United States · 1941

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

3Cited by20 opinions

  1. Helvering v. StuartSupreme Court of the United States · 1942
  2. Central Nat. Bank v. Com'r of Internal RevenueCourt of Appeals for the Sixth Circuit · 1944
  3. Miller v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1945
  4. Hogle v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1942
  5. Price v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1942

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

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