Legal Opinion
Columbus Bank & Trust Co. v. United States
District Court, M.D. Georgia
Decided September 20, 1962No. Civ. A. No. 853Published
1Opinion of the Court
ELLIOTT, District Judge.
The sole issue in this case is whether the income of two trusts created by C. F. Williams was taxable to him as the grantor-trustee of the trusts for the years 1953 and 1954 by virtue of the provisions of Internal Revenue Code of 1939 and in particular U. S. Treas.Regs. § 39.22 (a)-21. The parties concede that if the income of the trusts was not taxable to the grantor-trustee during 1953 and 1954, the plaintiffs (taxpayers) are entitled to recover from the Government overpayments of income tax as alleged.
On August 8, 1961 taxpayers filed a motion for summary judgment,…
2Cases cited8 opinions
- Armstrong v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1944
- Miller v. Commissioner of Internal Revenue (Two Cases)Court of Appeals for the Sixth Circuit · 1953
- United States v. MorssCourt of Appeals for the First Circuit · 1947
- W. Sam Edwards, Administrator of the Estate of Marion H. Allen, Former Collector of Internal Revenue v. Mrs. Dorothy Dannenberg GreenwaldCourt of Appeals for the Fifth Circuit · 1954
- Wofford v. Commissioner of Internal Revenue. Commissioner of Internal Revenue v. WoffordCourt of Appeals for the Fifth Circuit · 1953
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