Union Trust Co. v. Commissioner of Internal Revenue
Court of Appeals for the Third Circuit
1Opinion of the Court
CLARK, Circuit Judge.
Appellant’s actual complaint is against a confusion of definition. The tax collector, the economists, the Congress, and the United States Supreme Court have not been altogether in accord on the tax meaning of “income”. The bewilderment has been augmented by a constitutional and practical necessity of ■ interpreting each other’s theories. Our category and therefore obligation is simpler. We need consider only the opinions of our highest court.
To the tax collector, all receipts are income.1 An exception to even his enthusiasm used to but no longer prevails. It is amusingly…
2Cases cited13 opinions
- Irwin v. GavitSupreme Court of the United States · 1925
- Helvering v. ButterworthSupreme Court of the United States · 1933
- Merchants' Loan & Trust Co. v. SmietankaSupreme Court of the United States · 1921
- Burnet v. WhitehouseSupreme Court of the United States · 1931
- Hartford-Connecticut Trust Co. v. EatonCourt of Appeals for the Second Circuit · 1929
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3Cited by5 opinions
- Coleman v. CommissionerCourt of Appeals for the Third Circuit · 1945
- Goodwin v. Hartford Life Insurance CompanyDistrict Court, W.D. Pennsylvania · 1973
- Frank H. Mason Trust v. CommissionerCourt of Appeals for the Sixth Circuit · 1943
- Coleman v. CommissionerCourt of Appeals for the Third Circuit · 1945
- Rieck v. CommissionerCourt of Appeals for the Third Circuit · 1941