Legal Opinion

Commissioner of Internal Revenue v. Estate of Harry A. Ellis, Deceased, Helen R. Ellis, Bernard B. Largman and Dan Denenberg, Executors

Court of Appeals for the Third Circuit

Decided January 31, 1958No. 12248_1PublishedCited by 51 opinions

1Opinion of the Court

BIGGS, Chief Judge.

On this review we are called upon to determine the application of Section 812 (e) (1) (F), and, alternatively, that of Section 812(e) (1) (A) of the Internal Revenue Code of 1939, 1 in respect to federal estate taxes. Ellis, the decedent, a resident of Pennsylvania, died testate on July 30, 1951, survived by his wife, Helen. His will provided in pertinent part, as follows:

“All the rest, residue and remainder of my estate, real and personal, more particularly my interest in the partnership by and between Albert E. Hughes, Jr., and myself, trading as Philadelphia…

2Cases cited16 opinions

  1. Morgan v. CommissionerSupreme Court of the United States · 1940
  2. Helvering v. StuartSupreme Court of the United States · 1942
  3. Estate of TysonSupreme Court of Pennsylvania · 1899
  4. Estate of Edward F. Pipe, Deceased, Nettie M. Pipe v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1957
  5. T. Everett Starrett v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1955

11 more not listed; retrieve them via the Exa API.

3Cited by51 opinions

  1. Jackson v. United StatesSupreme Court of the United States · 1964
  2. Rose Gelb, Victor Edwin Gelb, Manufacturers Trust Company, Executors, of the Estate of Harry Gelb v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1962
  3. Matthew Rives McGehee of the Estate of Delia Crawford McGehee Deceased v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1958
  4. Strite v. McGinnesCourt of Appeals for the Third Circuit · 1964
  5. Estate of Ralph G. May, Mildred K. May v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1960

46 more not listed; retrieve them via the Exa API.

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