Safe Deposit & Trust Co. of Baltimore v. Miles
District Court, D. Maryland
At Daw. Action by the Safe Deposit & Trust Company of Baltimore, guardian of Frank R. Brown, against Joshua W. Miles, Collector of Internal Revenue. Judgment for plaintiff.
1Opinion of the Court
ROSE, District Judge.
The plaintiff, the Safe Deposit & Trust Company of Baltimore, as guardian of one Frank R. Brown, an infant, sold for $12,546.80 the right to subscribe for 35 shares of the stock of the Hartford Fire Insurance Company. The defendant, as collector of internal revenue, insisted that this entire sum was taxable income of the ward, and demanded $1,130.77 as the tax thereon. The plaintiff paid it under protest, unavailingly appealed to the Commission*823er, and brought this suit. Its contention that what it received for the rights was capital, and not constitutionally taxable as…
2Cases cited5 opinions
- Eisner v. MacOmberSupreme Court of the United States · 1920
- Eisner, Internal Revenue Collector v. MacOmberSupreme Court of the United States · 1919
- Doyle v. Mitchell Brothers Co.Supreme Court of the United States · 1918
- Von Baumbach v. Sargent Land Co.Supreme Court of the United States · 1917
- Tax Commissioner v. PutnamMassachusetts Supreme Judicial Court · 1917
3Cited by16 opinions
- Miles v. Safe Deposit & Trust Co. of BaltimoreSupreme Court of the United States · 1922
- Towne v. McElligottDistrict Court, S.D. New York · 1921
- Schoenheit v. LucasCourt of Appeals for the Fourth Circuit · 1930
- Logan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Tsivoglou v. United StatesDistrict Court, D. Massachusetts · 1928
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