Legal Opinion
Commissioner of Internal Revenue v. Estate of Ellie G. Canfield, Deceased, Karl B. Smith, Jr., Administrator, C.T.A.
Court of Appeals for the Second Circuit
Decided June 25, 1962No. 145, Docket 26870PublishedCited by 28 opinions
1Opinion of the Court
MARSHALL, Circuit Judge.
This is a petition for review of a Tax Court decision upholding the respondent estate’s challenge to certain estate tax deficiencies asserted by petitioner. 1
The material facts were stipulated and the Tax Court summarized them as follows:
“Ellie G. Canfield, deceased, herein referred to as decedent, was born on August 2, 1863, and died on January 24, 1955. At the time of her death and at all other times material to this case she was domiciled in and a resident of the State of New York.
“Decedent’s husband, Francis D. Canfield, died on October 8, 1917. Decedent never…
2Cases cited20 opinions
- Corliss v. BowersSupreme Court of the United States · 1930
- Estate of Sanford v. CommissionerSupreme Court of the United States · 1939
- Reinecke v. Northern Trust Co.Supreme Court of the United States · 1929
- Hassett v. WelchSupreme Court of the United States · 1938
- May v. HeinerSupreme Court of the United States · 1930
15 more not listed; retrieve them via the Exa API.
3Cited by28 opinions
- Nassau Lens Co., Inc. v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. Harry Pildes and Sarah PildesCourt of Appeals for the Second Circuit · 1962
- Mull v. Colt Co.District Court, S.D. New York · 1962
- Estate of Marshall v. CommissionerUnited States Tax Court · 1969
- Judith Badgley v. United StatesCourt of Appeals for the Ninth Circuit · 2020
- Estate of Thomson v. CommissionerUnited States Tax Court · 1972
23 more not listed; retrieve them via the Exa API.