Legal Opinion
Commissioner of Internal Rev. v. Upjohn's Estate
Court of Appeals for the Sixth Circuit
Decided December 10, 1941No. 8877PublishedCited by 13 opinions
1Opinion of the Court
SIMONS, Circuit Judge.
William E. Upjohn, deceased, after making certain specific devises and bequests by will, left the entire residue of his estate in trust for certain charitable uses. The excess income of the trust which would become part of the residue, was asserted, by the trustee, to be deductible from the taxable income of the trust as an amount permanently set aside or to be used for the purposes described in § 162(a) of the Revenue Act of 1934, and its counterpart in the Revenue Act of 1936, 26 U.S.C.A. Int.Rev.Code, § 162(a). The Commissioner disallowed the deductions in the denial…
2Cases cited12 opinions
- Ould v. Washington Hospital for FoundlingsSupreme Court of the United States · 1877
- Humes v. United StatesSupreme Court of the United States · 1928
- United States v. Provident Trust Co.Supreme Court of the United States · 1934
- Lederer v. StocktonSupreme Court of the United States · 1922
- Gammons v. HassettCourt of Appeals for the First Circuit · 1941
7 more not listed; retrieve them via the Exa API.
3Cited by13 opinions
- Danz v. CommissionerUnited States Tax Court · 1952
- Keasbey & Mattison Co. v. RothensiesCourt of Appeals for the Third Circuit · 1943
- Commissioner of Internal Revenue v. Citizens & Southern Nat. BankCourt of Appeals for the Fifth Circuit · 1945
- Arthur Jordan Foundation v. Commissioner of Internal ReveuneCourt of Appeals for the Seventh Circuit · 1954
- Commissioner v. Merchants Nat. BankCourt of Appeals for the First Circuit · 1942
8 more not listed; retrieve them via the Exa API.