Legal Opinion

Miller v. United States

District Court, W.D. Pennsylvania

Decided April 19, 1967No. Civ. A. 66-188PublishedCited by 6 opinions

1Opinion of the Court

OPINION

DUMBAULD, District Judge.

It is agreed by both parties that the solution to the problems presented by the case at bar is to be found in the principles set forth in Strite v. McGinnes, 330 F.2d 234 (C.A.3, 1964), and Security-Peoples Trust Co. v. United States, 238 F.Supp. 40 (W.D.Pa.1965). But, understandably, they differ as to the conclusion which those principles require with respect to the facts of the case at bar.

The question for determination is whether certain trust property is includible for estate tax purposes in the estate of the cestui que trust. A deficiency has been asserted…

2Cases cited7 opinions

  1. Olmstead v. United StatesSupreme Court of the United States · 1928
  2. Johnson v. United StatesCourt of Appeals for the First Circuit · 1908
  3. City of Yonkers v. United StatesSupreme Court of the United States · 1944
  4. Strite v. McGinnesCourt of Appeals for the Third Circuit · 1964
  5. Hanover Shoe, Inc. v. United Shoe MacHinery Corp.District Court, M.D. Pennsylvania · 1960

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

3Cited by6 opinions

  1. Horace S. Miller, Jr. And Isabel M. Campbell, Co-Executors of the Estate of Isabella Steel Miller, Deceased v. United StatesCourt of Appeals for the Third Circuit · 1968
  2. Estate of NunnCalifornia Supreme Court · 1974
  3. Estate of Towle v. CommissionerUnited States Tax Court · 1970
  4. Pittsburgh National Bank v. United StatesDistrict Court, W.D. Pennsylvania · 1970
  5. Flournoy v. Beverly Hills National BankCalifornia Supreme Court · 1974

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

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