Legal Opinion
The Citizen's National Bank of Waco, Trustee v. United States
Court of Appeals for the Fifth Circuit
Decided October 3, 1969No. 26796_1PublishedCited by 30 opinions
1Opinion of the Court
GOLDBERG, Circuit Judge:
In this tax case we are confounded by the jargon of the regulations, unassisted by guiding case law, and confronted with an enacting environment singularly un-illuminating. The issue presented is whether for the purpose of determining the holding periods of several trusts, the taxpayer-trustee is entitled to tack the settlors’ holding periods to those of the trusts.
The settlors acquired all of the capital stock of Bosque Investment Company in 1950. Several years later, they borrowed $500,000, pledging this stock as collateral for the loan. Shortly after-wards they…
2Cases cited7 opinions
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- United States v. CorrellSupreme Court of the United States · 1967
- Fawcus MacHine Co. v. United StatesSupreme Court of the United States · 1931
- United States v. CalamaroSupreme Court of the United States · 1957
- Turner v. CommissionerUnited States Tax Court · 1968
2 more not listed; retrieve them via the Exa API.
3Cited by30 opinions
- Minahan v. CommissionerUnited States Tax Court · 1987
- CWT Farms, Inc. v. CommissionerUnited States Tax Court · 1982
- Truck & Equipment Corp. v. CommissionerUnited States Tax Court · 1992
- Durbin Paper Stock Co. v. CommissionerUnited States Tax Court · 1983
- Hefti v. CommissionerUnited States Tax Court · 1991
25 more not listed; retrieve them via the Exa API.