Haller v. Commissioner
United States Board of Tax Appeals
1. The evidence failed to prove that in the taxable years an agreement of partnership existed between petitioner and her six children. 2. An earlier decision of the Board involving the same petitioner and the same general questions for previous tax years is conclusive as to the questions litigated for those years. The identical question having been involved, that decision is conclusive as to the construction of the will of petitioner's decedent.
1Opinion of the Court
*399OPINION,
Van Fossan :
In Mary Haller, 14 B. T. A. 488, deficiencies in the income taxes of the present petitioner for the years 1917 to 1923, inclusive, were in controversy. In opposing those deficiencies the petitioner contended, among other things, that “ under the will of Jacob Haller construed in the light of surrounding circumstances at the time of his death one-seventh of the income is distributable to her and one-seventh to each of the six children who were living during the taxable years.” Substantially the same contention is made in the present proceeding. In our former decision we…
2Cases cited5 opinions
- Cromwell v. County of SacSupreme Court of the United States · 1877
- Southern Pacific Railroad v. United StatesSupreme Court of the United States · 1897
- Russell v. PlaceSupreme Court of the United States · 1877
- Northern Pacific Railway Co. v. SlaghtSupreme Court of the United States · 1907
- Allen-West Commission Co. v. GrumblesCourt of Appeals for the Eighth Circuit · 1904
3Cited by9 opinions
- Frelbro Corp. v. CommissionerUnited States Tax Court · 1961
- Leininger v. CommissionerUnited States Board of Tax Appeals · 1934
- Pelham Hall Co. v. CarneyDistrict Court, D. Massachusetts · 1939
- Portage Silica Co. v. CommissionerUnited States Board of Tax Appeals · 1934
- Marshall v. CommissionerUnited States Board of Tax Appeals · 1934
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