Legal Opinion
Helvering v. Wilmington Trust Co.
Court of Appeals for the Third Circuit
Decided September 3, 1941No. 7662PublishedCited by 24 opinions
1Opinion of the Court
CLARK, Circuit Judge.
Taxpayer maintained several security accounts with her brokers. In computing her income tax for 1934 and 1935 taxpayer deducted the sums charged as dividends to her short account from the dividend credits on her long accounts. The Commissioner of Internal Revenue assessed a deficiency for the amount of the deduction on the theory that the accounts were separate. The Board of Tax Appeals refused to uphold the deficiency because it viewed the separation of taxpayer’s accounts into long and short accounts as a mere bookkeeping device. It also held that if it were wrong in…
2Cases cited22 opinions
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Flint v. Stone Tracy Co.Supreme Court of the United States · 1911
- Higgins v. CommissionerSupreme Court of the United States · 1941
- Helvering v. WinmillSupreme Court of the United States · 1938
- United States v. PyneSupreme Court of the United States · 1941
17 more not listed; retrieve them via the Exa API.
3Cited by24 opinions
- Putnam v. CommissionerSupreme Court of the United States · 1956
- Wilmington Trust Co. v. HelveringSupreme Court of the United States · 1942
- City of Los Angeles v. Pacific Telephone & Telegraph Co.California Court of Appeal · 1958
- Richard Gajewski v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1983
- Commissioner v. WieslerCourt of Appeals for the Sixth Circuit · 1947
19 more not listed; retrieve them via the Exa API.