De Coppet v. Commissioner
United States Board of Tax Appeals
1. The shareholders of a bank were entitled to share, through a trust, in dividends and cash distributions of an investment corporation which the bank had organized to engage in activities forbidden to it. The investment corporation's shares, always kept equal in number to outstanding bank shares, were owned by trustees, required to be bank directors or officers, and the corporation's activities were controlled by the bank's directors.
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1. The shareholders of a bank were entitled to share, through a trust, in dividends and cash distributions of an investment corporation which the bank had organized to engage in activities forbidden to it. The investment corporation's shares, always kept equal in number to outstanding bank shares, were owned by trustees, required to be bank directors or officers, and the corporation's activities were controlled by the bank's directors. The shareholders' rights under the trust were inseparable from their ownership of bank shares, and were evidenced only by an endorsement on their bank share…
1Opinion of the Court
ANDRE DECOPPET AND MURIEL DECOPPET, PETITIONERS, ET AL., 1v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
De Coppet v. Commissioner
Docket Nos. 85685, 85877, 85965, 85985, 86202, 86203, 86796, 86818.
United States Board of Tax Appeals
38 B.T.A. 1381; 1938 BTA LEXIS 745;
December 15, 1938, Promulgated
1. The shareholders of a bank were entitled to share, through a trust, in dividends and cash distributions of an investment corporation which the bank had organized to engage in activities forbidden to it. The investment corporation's shares, always kept equal in number to outstanding bank shares,…
2Cases cited2 opinions
- Hagerman v. CommissionerUnited States Board of Tax Appeals · 1936
- De Coppet v. CommissionerUnited States Board of Tax Appeals · 1938