Legal Opinion
John R. Upton, Anna L. S. Upton and Margaret St. Aubyn v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided December 19, 1960No. 16703PublishedCited by 22 opinions
1Opinion of the Court
HAMLEY, Circuit Judge.
The named petitioners seek reversal of two decisions of the Tax Court rendered in consolidated proceedings to redetermine tax deficiencies and reported in 32 T.C. 301. The principal question presented here relates to the apportionment of percentage depletion allowances as between the life beneficiaries and the trustees of a testamentary trust in computing federal income taxes on oil well royalties.
The testator, William R. Sloan, died on April 14, 1923, leaving his widow, Agnes G. Sloan, and two daughters, Anna L. Sloan (now Upton) and Margaret R. Sloan (now St. Aubyn).…
2Cases cited7 opinions
- Crane v. CommissionerSupreme Court of the United States · 1947
- Gallagher v. SmithCourt of Appeals for the Third Circuit · 1955
- Commissioner of Internal Revenue v. NetcherCourt of Appeals for the Seventh Circuit · 1944
- Carol v. CommissionerUnited States Board of Tax Appeals · 1934
- Upton v. CommissionerUnited States Tax Court · 1959
2 more not listed; retrieve them via the Exa API.
3Cited by22 opinions
- Manuel M. Ellis v. Victor Carter, Etc.Court of Appeals for the Ninth Circuit · 1961
- James Ewing v. J. D. Williams, Warden, Metropolitan Correctional Center (United States of America, Real Party in Interest)Court of Appeals for the Ninth Circuit · 1979
- Stanley Halprin v. United StatesCourt of Appeals for the Ninth Circuit · 1961
- Estate of SloanCalifornia Court of Appeal · 1963
- Chapman v. Pier 1 Imports (U.S.) Inc.Court of Appeals for the Ninth Circuit · 2011
17 more not listed; retrieve them via the Exa API.