Legal Opinion

Peoples Loan & Trust Co. v. Commissioner

United States Tax Court

Decided October 26, 1987No. Docket Nos. 30402-84, 30420-84Published

M operated NCEA as a membership organization. M accepted deposits from members, acquired precious metals with such funds, and paid such members' bills in cash. M died in 1983. At his death, H, a coin dealer, and PL, a bank, were in possession of precious metals and cash held for M or for his clients. PL was subsequently appointed administrator of M's estate in Indiana.

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M operated NCEA as a membership organization. M accepted deposits from members, acquired precious metals with such funds, and paid such members' bills in cash. M died in 1983. At his death, H, a coin dealer, and PL, a bank, were in possession of precious metals and cash held for M or for his clients. PL was subsequently appointed administrator of M's estate in Indiana. Members of NCEA filed claims against the estate, seeking return of the precious metals purchased by M on their behalf, and N, a bank in Colorado, commenced an action in a Federal court in Indiana seeking to determine the…

1Opinion of the Court

Peoples Loan & Trust Co., as Possessor of Certain Cash, Petitioner v. Commissioner of Internal Revenue, Respondent; Leon E. Hendrickson, as Possessor of Certain Cash, Petitioner v. Commissioner of Internal Revenue, Respondent

Peoples Loan & Trust Co. v. Commissioner

Docket Nos. 30402-84, 30420-84

United States Tax Court

89 T.C. 896; 1987 U.S. Tax Ct. LEXIS 151; 89 T.C. No. 62;

October 26, 1987; Reversed and Remanded April 27, 1989 October 26, 1987, Filed

M operated NCEA as a membership organization. M accepted deposits from members, acquired precious metals with such funds, and paid such members'…

Also in this document: Dissent.

2Cases cited10 opinions

  1. Abrams v. CommissionerUnited States Tax Court · 1984
  2. Helvering v. ReynoldsSupreme Court of the United States · 1941
  3. Durovic v. CommissionerUnited States Tax Court · 1970
  4. Marko Durovic v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1973
  5. Shelton v. CommissionerUnited States Tax Court · 1974

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