Legal Opinion

Boeing v. Commissioner

United States Board of Tax Appeals

Decided June 2, 1942No. Docket Nos. 94779, 95704Published

These proceedings were originally decided in favor of petitioner upon the ground that the beneficiaries of the trust and not the trust itself were the donees of the gifts. The Commissioner petitioned for review to the Circuit Court of Appeals for the Ninth Circuit. That court reversed the Board upon the grounds that the gifts were of "future interests", an issue which was not raised by the Commissioner at the time of the hearing before the Board.

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These proceedings were originally decided in favor of petitioner upon the ground that the beneficiaries of the trust and not the trust itself were the donees of the gifts. The Commissioner petitioned for review to the Circuit Court of Appeals for the Ninth Circuit. That court reversed the Board upon the grounds that the gifts were of "future interests", an issue which was not raised by the Commissioner at the time of the hearing before the Board. The mandate of the court directs the Board to take further proceedings in the said cause "in accordance with the opinion and judgment of this…

1Opinion of the Court

WILLIAM E. BOEING, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Boeing v. Commissioner

Docket Nos. 94779, 95704.

United States Board of Tax Appeals

47 B.T.A. 5; 1942 BTA LEXIS 752;

June 2, 1942, Promulgated

These proceedings were originally decided in favor of petitioner upon the ground that the beneficiaries of the trust and not the trust itself were the donees of the gifts. The Commissioner petitioned for review to the Circuit Court of Appeals for the Ninth Circuit. That court reversed the Board upon the grounds that the gifts were of "future interests", an issue which was not…

2Cases cited2 opinions

  1. Boeing v. CommissionerUnited States Board of Tax Appeals · 1942
  2. Boeing v. CommissionerUnited States Board of Tax Appeals · 1942

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