Legal Opinion
Fidelity-Philadelphia Trust Co. v. Commissioner of Int. Rev.
Court of Appeals for the Third Circuit
Decided February 7, 1931No. 4429PublishedCited by 13 opinions
1Opinion of the Court
WOOLLEY, Circuit Judge.
Jaeob K. Smith, who died in 1884, devised his real estate to a trustee to be held and, when occasion should arise, to be sold and the proceeds held under the trusts and distributed upon the happening of a future event.
In 1923 the trustee, petitioner in this case, sold several tracts of improved real estate, the buildings on which had an agreed value of $214,500.00 as of March 1, 1913. In its income tax returns through the years the trustee had not made deductions for depreciation and in calculating profits on the sale of real estate in the tax return in question, it…
2Cases cited5 opinions
- United States v. LudeySupreme Court of the United States · 1927
- Weiss v. WeinerSupreme Court of the United States · 1929
- United States v. RobbinsSupreme Court of the United States · 1926
- Burk-Waggoner Oil Assn. v. HopkinsSupreme Court of the United States · 1925
- Hardwick Realty Co. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1928
3Cited by13 opinions
- Heiner v. MellonSupreme Court of the United States · 1938
- Virginian Hotel Corporation v. Helvering, Commissioner of Internal RevenueSupreme Court of the United States · 1943
- Hart v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1932
- Cleaver v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1946
- Angelus Building & Investment Co. v. Com'r of Int. Rev.Court of Appeals for the Ninth Circuit · 1932
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