Legal Opinion
Empire Trust Company v. United States
District Court, S.D. New York
Decided December 26, 1963PublishedCited by 3 opinions
1Opinion of the Court
LEVET, District Judge.
This is a suit for refund of federal estate taxes. This court has jurisdiction of the action under 28 U.S.C. § 1346(a) (1). Plaintiffs, as executors of the estate of Harold R. Mixsell, deceased, bring this action to recover $45,561.61 of estate tax and $4,911.29 of deficiency interest paid by them to the Internal Revenue Service on March 31, 1961. Three separate and distinct issues are raised in this suit for refund. Two of the issues, whether certain gifts were made in contemplation of death and whether the Commissioner erroneously disallowed a charitable deduction…
2Cases cited14 opinions
- Tilden v. . GreenNew York Court of Appeals · 1891
- Oklahoma Tax Commission v. United StatesSupreme Court of the United States · 1943
- In Re the Accounting of TamargoNew York Court of Appeals · 1917
- Estate of Harrison P. Shedd, Deceased First National Bank of Arizona, Phoenix v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1956
- Commissioner of Internal Revenue v. Estate of Harry A. Ellis, Deceased, Helen R. Ellis, Bernard B. Largman and Dan Denenberg, ExecutorsCourt of Appeals for the Third Circuit · 1958
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3Cited by3 opinions
- Hamilton National Bank of Chattanooga v. United StatesDistrict Court, E.D. Tennessee · 1965
- Patton v. FulmerCourt of Appeals of Arkansas · 2016
- Estate of Sobota v. CommissionerUnited States Tax Court · 1996