Legal Opinion
Estate of Charlotte D. M. Cardeza, Deceased. Fidelity-Philadelphia Trust Company, in No. 12569 v. United States of America, in No. 12570
Court of Appeals for the Third Circuit
Decided November 14, 1958No. 12570_1PublishedCited by 5 opinions
1Opinion of the Court
STALEY, Circuit Judge.
These appeals present another aspect of the litigation regarding the taxes paid by the Cardeza Estate. The decedent, during her lifetime, transferred a substantial amount of money to a trust established by the will of her father. The decedent’s children and their issue were the primary beneficiaries of one-third of this trust. However, if the decedent survived all her children and their issue she became entitled to the income of that share for life with a testamentary power of appointment over the corpus.
In an earlier opinion, Cardeza’s Estate v. C. I. R., 1949, 173 F.2d…
2Cases cited10 opinions
- Humes v. United StatesSupreme Court of the United States · 1928
- Commissioner v. Estate of SternbergerSupreme Court of the United States · 1955
- Robinette v. HelveringSupreme Court of the United States · 1943
- Commissioner of Internal Revenue v. MaresiCourt of Appeals for the Second Circuit · 1946
- Brotherhood of Locomotive Firemen & Enginemen v. PinkstonSupreme Court of the United States · 1934
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3Cited by5 opinions
- Graham v. CommissionerUnited States Tax Court · 1966
- Hanover Bank and Samuel B. Fortenbaugh, Jr., Executors of Estate of William F. Wall, Deceased v. United StatesUnited States Court of Claims · 1961
- Bankers Trust Company v. United StatesDistrict Court, S.D. New York · 1960
- Graham v. CommissionerUnited States Tax Court · 1966
- Hanover Bank and Samuel B. Fortenbaugh, Jr., Executors of Estate of William F. Wall, Deceased v. United StatesUnited States Court of Claims · 1961