Legal Opinion
Commissioner of Internal Revenue v. Hart
Court of Appeals for the Third Circuit
Decided July 28, 1939No. 6819PublishedCited by 8 opinions
1Opinion of the Court
CLARK, Circuit Judge.
This is the kind of case in which decision affords little, if any, intellectual satisfaction. It involves the application of the Act of Congress taxing gifts, 26 U.S.C.A. § 550(b), to the creation of an estate by the entireties. The words of the statute are broad and general, being: “The tax shall apply whether the transfer is in trust or otherwise, whether the gift is direct or indirect, and whether the property is real or personal, tangible or intangible”. The legal circumstance is narrow and particular. It is difficult to determine the exact scope of their…
2Cases cited28 opinions
- Tyler v. United StatesSupreme Court of the United States · 1930
- Burnet v. GuggenheimSupreme Court of the United States · 1933
- Saltonstall v. SaltonstallSupreme Court of the United States · 1928
- United States v. JacobsSupreme Court of the United States · 1939
- Coolidge v. LongSupreme Court of the United States · 1931
23 more not listed; retrieve them via the Exa API.
3Cited by8 opinions
- Commissioner of Internal Revenue v. MarshallCourt of Appeals for the Second Circuit · 1942
- Herzog v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1941
- Hopkins v. MagruderDistrict Court, D. Maryland · 1940
- Commissioner of Internal Revenue v. LoganCourt of Appeals for the Third Circuit · 1940
- Commissioner v. LoganCourt of Appeals for the Third Circuit · 1940
3 more not listed; retrieve them via the Exa API.