Legal Opinion

Yagoda v. Commissioner

United States Tax Court

Decided October 22, 1962No. Docket Nos. 82641, 82642, 82643, 82644Published

1. Held, mitigation of limitations provisions (secs. 1311- 1314, I.R.C. 1954) applicable to adjustments made by the Commissioner. 2. Held, further, that, in the circumstances of this case, no present transferee liability exists in respect of one of the petitioners (Lena Drechsler) where transferor's taxes had previously been fully paid. 3. Held, further, that Elaine Yagoda is liable as transferee of trust for her benefit. Extent of liability determined.

1Opinion of the Court

Elaine Yagoda (Formerly Elaine Drechsler), et al., 1 Petitioners, v. Commissioner of Internal Revenue, Respondent

Yagoda v. Commissioner

Docket Nos. 82641, 82642, 82643, 82644

United States Tax Court

39 T.C. 170; 1962 U.S. Tax Ct. LEXIS 46;

October 22, 1962, Filed

Decisions in Docket Nos. 82641, 82643, and 82644 will be entered under Rule 50.

Decision in Docket No. 82642 will be entered for the respondent.

1. Held, mitigation of limitations provisions (secs. 1311- 1314, I.R.C. 1954) applicable to adjustments made by the Commissioner.

2. Held, further, that, in the circumstances of this case, no…

2Cases cited19 opinions

  1. Estate of Sanford v. CommissionerSupreme Court of the United States · 1939
  2. Swift & Co. v. Hocking Valley Railway Co.Supreme Court of the United States · 1917
  3. Scott v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1941
  4. Yagoda v. CommissionerUnited States Tax Court · 1962
  5. Estate of Cury v. CommissionerUnited States Tax Court · 1954

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