Legal Opinion
Fidelity—Philadelphia Trust Co. v. Commissioner
Court of Appeals for the Third Circuit
Decided January 31, 1940No. 7239PublishedCited by 8 opinions
1Opinion of the Court
BIGGS, Circuit Judge.
The Board of Tax Appeals has entered its decision against the petitioners, finding a deficiency in the sum of $121,936 in estate tax. The petitioners have appealed to this court for a review of the Board’s decision.
The pertinent facts are as follows. Sidney F. Tyler died upon June 3, 1935. Upon April 22, 1885, he transferred certain personal property in trust, the income of which was to be paid in equal shares to his two children and to the issue per stirpes of either child predeceasing the other. The settlor also provided by the indenture that the trust was to come to an…
2Cases cited9 opinions
- Estate of Sanford v. CommissionerSupreme Court of the United States · 1939
- Porter v. CommissionerSupreme Court of the United States · 1933
- Hesslein v. HoeyCourt of Appeals for the Second Circuit · 1937
- Cook v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1933
- Hubbell v. BurnetCourt of Appeals for the Eighth Circuit · 1931
4 more not listed; retrieve them via the Exa API.
3Cited by8 opinions
- Guggenheim v. HelveringCourt of Appeals for the Second Circuit · 1941
- Mellon v. DriscollCourt of Appeals for the Third Circuit · 1941
- Rhode Island Hospital Trust Company v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1955
- Steere v. CommissionerUnited States Tax Court · 1954
- Commissioner of Internal Rev. v. Hofheimer's EstateCourt of Appeals for the Second Circuit · 1945
3 more not listed; retrieve them via the Exa API.