Legal Opinion

Commissioner of Internal Revenue v. Chase Nat. Bank

Court of Appeals for the Second Circuit

Decided August 14, 1941No. 233-236PublishedCited by 24 opinions

1Opinion of the Court

CHASE, Circuit Judge.

Four petitions to review decisions of the Board of Tax Appeals redetermining deficiencies in the income taxes for 1934 of four separate investment trusts were consolidated and heard together.

The Chase National Bank of the City of New York is the trustee of each trust created by an agreement made with it by the American Depositor Corporation, a New York corporation with its principal office in the City of New York. The Commissioner determined that each trust was to be classed as an association whose income was taxable, under Sec. 801 (a) of the Revenue Act of 1934, 26…

2Cases cited4 opinions

  1. Helvering v. National Grocery Co.Supreme Court of the United States · 1938
  2. Morrissey v. CommissionerSupreme Court of the United States · 1935
  3. Sears v. HassettCourt of Appeals for the First Circuit · 1940
  4. Ittleson v. AndersonCourt of Appeals for the Second Circuit · 1933

3Cited by24 opinions

  1. Retirement Board of the Policemen's Annuity & Benefit Fund v. Bank of New York MellonCourt of Appeals for the Second Circuit · 2014
  2. Smith v. CommissionerUnited States Tax Court · 1959
  3. Commissioner of Internal Revenue v. North American Bond TrustCourt of Appeals for the Second Circuit · 1941
  4. Penna. Co., Etc., Tr. v. Phila.Supreme Court of Pennsylvania · 1943
  5. Commissioner of Internal Rev. v. City Nat. Bank & T. Co.Court of Appeals for the Tenth Circuit · 1944

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