Legal Opinion
Charles S. Dovey, Sr. v. United States of America. Emma R. Dovey, of the Estate of Francis S. Dovey, Deceased v. United States
Court of Appeals for the Third Circuit
Decided April 21, 1958No. 12359, 12360PublishedCited by 4 opinions
1Opinion of the Court
HASTIE, Circuit Judge.
These are actions for tax refunds, brought by beneficiaries under a simple or currently distributable trust to recover amounts paid by them under protest as income taxes on certain distributions made to them by the trustees. The trust was set up by the will of Cecelia S. Brill, who died in 1937. The corpus of the trust included 1690 shares of 7% cumulative preferred stock in the Brill Corporation, worth at the time of the settlor’s death about $64,000. In 1944, the Brill Corporation merged with the American Car and Foundry Motors Company, and shortly thereafter the Brill…
2Cases cited4 opinions
- Irwin v. GavitSupreme Court of the United States · 1925
- Johnston v. HelveringCourt of Appeals for the Second Circuit · 1944
- McCullough v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1946
- Johnston v. CommissionerSupreme Court of the United States · 1944
3Cited by4 opinions
- The South Bay Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1965
- Commissioner of Internal Revenue v. Adelaide D. J. BurgwinCourt of Appeals for the Third Circuit · 1960
- Mary Pauline McKenney Joyce, Aloysius G. Casey and Gerard A. McDonough and Executors Under the Will of M. Pauline Casey, Deceased v. United StatesCourt of Appeals for the Third Circuit · 1966
- Mary Pauline McKenney Joyce, Aloysius G. Casey and Gerard A. McDonough and Executors Under the Will of M. Pauline Casey, Deceased v. United StatesCourt of Appeals for the Third Circuit · 1966