Legal Opinion

Fidelity Trust Co. v. Lederer

District Court, E.D. Pennsylvania

Decided July 14, 1921No. 8118PublishedCited by 5 opinions

At Law. Action by the Fidelity Trust Company against Ephraim Eederer, Collector o£ Internal Revenue. Sur rule for judgment. Rule discharged.

1Opinion of the Court

DICKINSON, District Judge.

This case is in effect a case stated, in the determination of which we are asked to decide a question of law. The question, broadly stated, is whether the “certificates” held by the plaintiff as trustee are taxable. We, in consequence, limit our attention to this.

[1] The taxing authorities give the impression of their attitude as, first, one of uncertainty and then one of doubt. We have given the subject of the tax the name of “certificates,” in order to get a word as colorless as possible, because any word or words definitely descriptive of what the thing sought to…

2Cases cited1 opinion

  1. United States v. IshamSupreme Court of the United States · 1873

3Cited by5 opinions

  1. Willcuts v. Investors' SyndicateCourt of Appeals for the Eighth Circuit · 1932
  2. Fidelity Investment Ass'n v. United StatesUnited States Court of Claims · 1933
  3. Investors' Syndicate v. WillcutsDistrict Court, D. Minnesota · 1930
  4. General Motors Acceptance Corp. v. HigginsDistrict Court, S.D. New York · 1945
  5. Hamilton Nat. Bank v. United StatesDistrict Court, D. Tennessee · 1936

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