Legal Opinion
Security Trust Co. v. Commissioner of Internal Revenue
Court of Appeals for the Sixth Circuit
Decided June 29, 1933No. Nos. 6266, 6267PublishedCited by 4 opinions
1Opinion of the Court
SIMONS, Circuit Judge.
The taxpayers in each ease are testamentary trustees. The question to be decided is whether the basis for determining gains derived by them on the sale of personal property received in trust as residuary legatees is the market value of the property at the time of its transfer to them by representatives of the estate under a probate court order of distribution, or the market value at the time of the testator’s death.
There is no dispute as to the facts, which are mainly stipulated. Horace E. and John P. Dodge, brothers, and founders of Dodge Bros., motor manufacturers,…
2Cases cited8 opinions
- Brewster v. GageSupreme Court of the United States · 1930
- Tyler v. United StatesSupreme Court of the United States · 1930
- Anderson v. WilsonSupreme Court of the United States · 1933
- Karnuth v. United States Ex Rel. AlbroSupreme Court of the United States · 1929
- District of Columbia v. FredSupreme Court of the United States · 1930
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3Cited by4 opinions
- Augustus v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1941
- Fidelity & Columbia Trust Co. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1937
- Williamson v. CommissionerCourt of Appeals for the Sixth Circuit · 1938
- Cooke v. United StatesDistrict Court, E.D. Pennsylvania · 1941