Legal Opinion

Manufacturers National Bank of Detroit v. United States

District Court, E.D. Michigan

Decided June 1, 1959No. Civ. A. No. 17137PublishedCited by 1 opinion

1Opinion of the Court

THORNTON, District Judge.

Plaintiff brings this suit to recover estate taxes paid by it as executor for the estate of Clifford B. Longley, who died July 15, 1954. The issue here is simply whether a section of the Internal Revenue Code of 1939, as amended, is unconstitutional as applied in this case. The identical question has been decided by several courts prior to this time, but there is a conflict in their decisions. It appears to us that there is no reconciliation possible and that we must reach a yes or no result. We shall proceed, therefore, to set forth the considerations which have led…

2Cases cited8 opinions

  1. United States v. BessSupreme Court of the United States · 1958
  2. Commissioner v. SternSupreme Court of the United States · 1958
  3. Jean F. Stern v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1957
  4. Tyson v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1954
  5. Anne Harley Kohl and William J. Harley, as Surviving Executors of the Estate of William S. Harley, Deceased, Etc. v. United StatesCourt of Appeals for the Seventh Circuit · 1955

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3Cited by1 opinion

  1. United States v. Manufacturers National Bank of DetroitSupreme Court of the United States · 1960

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