Legal Opinion

Commissioner of Internal Revenue v. Rivera's Estate

Court of Appeals for the Second Circuit

Decided June 10, 1954No. 202, Docket 22896PublishedCited by 10 opinions

1Opinion of the Court

MEDINA, Circuit Judge.

This appeal involves a federal estate tax assessed against the estate of Clo-tilde Santiago Rivera, deceased, and is taken from the decision of the Tax Court entered on March 2, 1953, determining that there is an overpayment in estate tax in the amount of $69,327.87, which was paid after the mailing of the notice of deficiency. The question presented on this appeal is whether or not Congress exempted from the federal estate tax assets situated in the continental United States belonging to the estate of a citizen of the United States and of Puerto Rico domiciled in Puerto…

2Cases cited8 opinions

  1. Downes v. BidwellSupreme Court of the United States · 1901
  2. Ex Parte Crow DogSupreme Court of the United States · 1883
  3. Rodgers v. United StatesSupreme Court of the United States · 1902
  4. United States v. JacksonSupreme Court of the United States · 1938
  5. United States v. Sixty-Seven Packages of Dry GoodsSupreme Court of the United States · 1855

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3Cited by10 opinions

  1. Commissioner of Internal Revenue v. Robert M. And Sally L. Bilder. Robert M. And Sally L. Bilder v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1961
  2. General Electric Credit Corp. v. James Talcott, Inc.District Court, S.D. New York · 1966
  3. In Re BrownDistrict Court, S.D. Iowa · 1971
  4. Fairchild v. CommissionerUnited States Tax Court · 1955
  5. Lavergne v. United States Casualty Co.District Court, D. Puerto Rico · 1966

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