Legal Opinion

Steuben Sec. Corp. v. Commissioner

United States Tax Court

Decided January 5, 1943No. Docket No. 106257Published

The word "beneficiaries" appearing in the description of constructive ownership of stock in a personal holding company means those persons who have present interests in a trust holding the shares and excludes those who have a remainder or other remote interest, whether vested or contingent.

1Opinion of the Court

Steuben Securities Corporation, Petitioner, v. Commissioner of Internal Revenue, Respondent

Steuben Sec. Corp. v. Commissioner

Docket No. 106257

United States Tax Court

1 T.C. 395; 1943 U.S. Tax Ct. LEXIS 259;

January 5, 1943, Promulgated

Decision will be entered for the respondent.

The word "beneficiaries" appearing in the description of constructive ownership of stock in a personal holding company means those persons who have present interests in a trust holding the shares and excludes those who have a remainder or other remote interest, whether vested or contingent.

William Flannery, Esq., and…

2Cases cited3 opinions

  1. Helvering v. CliffordSupreme Court of the United States · 1940
  2. Helvering v. HallockSupreme Court of the United States · 1940
  3. Steuben Sec. Corp. v. CommissionerUnited States Tax Court · 1943

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