Legal Opinion
Helvering v. Coleman-Gilbert Associates
Supreme Court of the United States
Decided December 16, 1935No. 78 and 79PublishedCited by 231 opinions
1Opinion of the CourtChief Justice Hughes
The Commissioner of Internal Revenue determined deficiencies in income taxes for the years 1927 to 1929 upon the ground that respondent was taxable as an association. The decision of the Board of Tax Appeals, sustaining this ruling, was reversed by the Circuit Court of Appeals. 76 F. (2d) 191. In view of the conflict of decisions as to the test to be applied, we granted certiorari. See Morrissey v. Commissioner, ante, p. 344.
From the facts, as found by the Board of Tax Appeals, it appears that respondent was formed by an indenture of trust in November, 1926. The creators of the trust were…
2Cited by231 opinions
- Bartels v. BirminghamSupreme Court of the United States · 1947
- Grace Bros. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1949
- Hynes v. CommissionerUnited States Tax Court · 1980
- A. A. Lewis & Co. v. CommissionerSupreme Court of the United States · 1937
- Estate of Craig M. Smith, Deceased, Ruth E. Smith v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1963
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