Legal Opinion
United States v. S. L. Rothenberg and Helen Rothenberg
Court of Appeals for the Tenth Circuit
Decided August 30, 1965No. 8094PublishedCited by 12 opinions
1Opinion of the Court
PICKETT, Circuit Judge.
The question presented in this appeal is whether corporate stock held by a trustee in an irrevocable trust for the benefit of a taxpayer’s minor child is owned by that child within the meaning of Section 1239 of the Internal Revenue Code of 1954. 26 U.S.C. § 1239. 1 The taxpayers, S. L. Rothenberg and his wife, Helen, brought this action for a refund of income taxes paid after the Commissioner of Internal Revenue had assessed a deficiency in their 1958 income tax, based upon a Treasury Regulation defining the statutory term “owner” as used in the statute. 2 This is an…
2Cases cited1 opinion
- Calvin D. Mitchell and Fay Bond Mitchell v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1962
3Cited by12 opinions
- Yamamoto v. CommissionerUnited States Tax Court · 1980
- Tosco Corp. v. HodelDistrict Court, D. Colorado · 1985
- Energy Reserves Group, Inc. v. Federal Energy AdministrationDistrict Court, D. Kansas · 1978
- Harry Trotz and Camille Trotz v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1966
- Shell Oil Co. v. KleppeDistrict Court, D. Colorado · 1977
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