Legal Opinion
Commonwealth Trust Co. of Pittsburgh v. United States
District Court, W.D. Pennsylvania
Decided April 6, 1951No. Civ. 7333, 7343PublishedCited by 8 opinions
1Opinion of the Court
GOURLEY, District Judge.
In connection with Civil Action No. 7333, government counsel has taken exception to the order entered July 13, 1949 which permitted the filing of an amended complaint.
The government contends:(1) The statute of limitations bars the amended complaint since it sets up a new cause of action.(2) The original complaint is fatally defective in that:(a) It does not set forth that the tax collector, to whom the income tax was paid, was dead at the time the proceeding was filed.(b) It does not set forth sufficient allegations of fact to establish the jurisdiction of the Court.
In…
2Cases cited15 opinions
- Estate of Sanford v. CommissionerSupreme Court of the United States · 1939
- Porter v. CommissionerSupreme Court of the United States · 1933
- United States v. LewisSupreme Court of the United States · 1951
- Smith v. ShaughnessySupreme Court of the United States · 1943
- Commissioner v. Estate of HolmesSupreme Court of the United States · 1946
10 more not listed; retrieve them via the Exa API.
3Cited by8 opinions
- De Franco v. United StatesDistrict Court, S.D. California · 1955
- Miriam Coward Pierson v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1958
- Boston Safe Deposit & Trust Co. v. State Tax CommissionMassachusetts Supreme Judicial Court · 1963
- Post v. CommissionerUnited States Tax Court · 1956
- Jorrie v. Imperial Investment CompanyDistrict Court, W.D. Texas · 1973
3 more not listed; retrieve them via the Exa API.