Legal Opinion
Cooper v. Commissioner of Internal Revenue
Court of Appeals for the Tenth Circuit
Decided November 28, 1958No. 5940PublishedCited by 5 opinions
1Opinion of the Court
PHILLIPS, Circuit Judge.
This is a petition to review a decision of the Tax Court. The petitioners are the John I. Cooper, H. W. Price and others Trust1 and H. W. Price and L. W. Price, trustees of such taxpayer trust. Deficiencies for the years 1950 to 1953, inclusive, are involved. The taxpayer trust filed fiduciary income tax returns for estates and trusts for such years. The Commissioner determined deficiencies on the ground that the taxpayer trust was analogous to a corporate organization and therefore taxable as an association under § 3797(a) (3) of the Internal Revenue Code of 1939, 26…
2Cases cited10 opinions
- Morrissey v. CommissionerSupreme Court of the United States · 1935
- Fletcher v. ClarkCourt of Appeals for the Tenth Circuit · 1945
- Commissioner of Internal Rev. v. Vandegrift R. & Inv. Co.Court of Appeals for the Ninth Circuit · 1936
- Commissioner of Internal Rev. v. City Nat. Bank & T. Co.Court of Appeals for the Tenth Circuit · 1944
- Commissioner of Internal Revenue v. Guitar Trust EstateCourt of Appeals for the Fifth Circuit · 1934
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3Cited by5 opinions
- Outlaw v. United StatesUnited States Court of Claims · 1974
- Mullendore Trust Company, by A. C. Adams, Mildred M. Adams and Bessie M. Johnson, Trustees v. United StatesCourt of Appeals for the Tenth Circuit · 1959
- John I. Cooper v. Commissioner Of Internal RevenueCourt of Appeals for the Tenth Circuit · 1959
- Stierwalt v. United StatesDistrict Court, D. Wyoming · 1960
- Allen v. CommissionerUnited States Tax Court · 1991