Wilson Trust v. Commissioner
United States Board of Tax Appeals
Under the facts in these proceedings, it is held that the Commissioner erred in holding the petitioner to be an association taxable as a corporation.
1Opinion of the Court
*553OPINION.
Black :
In this proceeding respondent has determined a deficiency against petitioner of $3,683.61 for the year 1924, stating his reasons therefor in the 60-day letter, as follows: “ Your contention that your organization is a trust and not an association has been denied, inasmuch as it has the general form, mode of procedure and effectiveness in action of a corporation and the beneficiaries have absolute control of its affairs, whether or not such control has been exercised by them.” Petitioner attacks this determination of the Commissioner in the following assignment of error: “ (a)…
2Cases cited5 opinions
- Flint v. Stone Tracy Co.Supreme Court of the United States · 1911
- Hecht v. MalleySupreme Court of the United States · 1924
- Burk-Waggoner Oil Assn. v. HopkinsSupreme Court of the United States · 1925
- United States v. Emery, Bird, Thayer Realty Co.Supreme Court of the United States · 1915
- Zonne v. Minneapolis SyndicateSupreme Court of the United States · 1911
3Cited by5 opinions
- Monrovia Oil Co. v. CommissionerUnited States Board of Tax Appeals · 1933
- Dauphin Deposit Trust Co. v. CommissionerUnited States Board of Tax Appeals · 1931
- Dunbar v. CommissionerUnited States Board of Tax Appeals · 1931
- Guitar Trust Estate v. CommissionerUnited States Board of Tax Appeals · 1932
- Wilson Trust v. CommissionerUnited States Board of Tax Appeals · 1930