Durfee Mineral Co. v. Commissioner
United States Board of Tax Appeals
The terms of a trust agreement, together with a conveyance of property to the trustees named therein, held to have created such an association as is subject to corporation income and profits taxes under the Revenue Act of 1918.
1Opinion of the Court
*242OPINION.
Smith:
The Commissioner’s deficiency notice was based on his decision that the petitioner was taxable as a trust estate under the provisions of section 219 of the Revenue Act of 1918, and as far as the record discloses such was his opinion until the matter came to trial. At the hearing counsel for the Commissioner substantially abandoned the position previously taken in the deficiency letter and in the stipulations, and argued that the Board find that the organization was a joint stock association and therefore taxable as a corporation under the Revenue Act of 1918.
This procedure was…
2Cases cited9 opinions
- Flint v. Stone Tracy Co.Supreme Court of the United States · 1911
- Hecht v. MalleySupreme Court of the United States · 1924
- Burk-Waggoner Oil Assn. v. HopkinsSupreme Court of the United States · 1925
- Zonne v. Minneapolis SyndicateSupreme Court of the United States · 1911
- Crocker v. MalleySupreme Court of the United States · 1919
4 more not listed; retrieve them via the Exa API.
3Cited by6 opinions
- Monrovia Oil Co. v. CommissionerUnited States Board of Tax Appeals · 1933
- Commercial Trust Co. v. CommissionerUnited States Board of Tax Appeals · 1930
- Durfee Mineral Co. v. CommissionerUnited States Board of Tax Appeals · 1927
- Dutton v. CommissionerUnited States Board of Tax Appeals · 1930
- E. A. Landreth Co. v. CommissionerUnited States Board of Tax Appeals · 1928
1 more not listed; retrieve them via the Exa API.