Legal Opinion

State Nat. Bank v. United States

District Court, W.D. Texas

Decided February 19, 1944Published

1Opinion of the Court

BOYNTON, District Judge.

Plaintiff, The State National Bank of El Paso, Texas, as Trustee of Pecos County Trust Estate, brings suit and action herein against defendant, United States of America, for refund of income taxes paid, recovery of income taxes, on assessments-made and collected by defendant of and from plaintiff for the years 1939 and 1940, assessed by the Commissioner of Internal-Revenue against plaintiff as a “corporation” or “association”, as an entity, paid under protest, plaintiff contending it was-subject to income only as a “trust” and not as a “corporation” or “association”…

2Cases cited7 opinions

  1. Morrissey v. CommissionerSupreme Court of the United States · 1935
  2. A. A. Lewis & Co. v. CommissionerSupreme Court of the United States · 1937
  3. Commissioner of Internal Rev. v. Horseshoe L. SyndicateCourt of Appeals for the Fifth Circuit · 1940
  4. Lucas v. Extension Oil Co.Court of Appeals for the Fifth Circuit · 1931
  5. Cleveland Trust Co. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1940

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