Steuben Sec. Corp. v. Commissioner
United States Tax Court
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
- Helvering v. CliffordSupreme Court of the United States · 1940
- Helvering v. HallockSupreme Court of the United States · 1940
- Steuben Sec. Corp. v. CommissionerUnited States Tax Court · 1943