Lansdowne Realty Trust v. Commissioner
United States Board of Tax Appeals
1. Articles 1502 and 1504, Reg. 62, 65, 69, defining associations and trusts, except for those organizations which fall unmistakably within one class or the other, must be interpreted not as an enumeration of express specifications, but rather as an outline of the more general attributes of the cases commonly dealt with. 2. Under them, holding trusts doing no business and occupied only in passively collecting income and distributing it are regarded as trusts; while those…
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1. Articles 1502 and 1504, Reg. 62, 65, 69, defining associations and trusts, except for those organizations which fall unmistakably within one class or the other, must be interpreted not as an enumeration of express specifications, but rather as an outline of the more general attributes of the cases commonly dealt with. 2. Under them, holding trusts doing no business and occupied only in passively collecting income and distributing it are regarded as trusts; while those which are actively engaged in business, conducted by representatives of the group of holders of transferable shares acting…
1Opinion of the Court
LANSDOWNE REALTY TRUST, ARTHUR H. TABER, WENDELL TABER, STURGIS COFFIN, TRUSTEES, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Lansdowne Realty Trust v. Commissioner
Docket Nos. 37478, 37479.
United States Board of Tax Appeals
20 B.T.A. 119; 1930 BTA LEXIS 2197;
June 24, 1930, Promulgated
1. Articles 1502 and 1504, Reg. 62, 65, 69, defining associations and trusts, except for those organizations which fall unmistakably within one class or the other, must be interpreted not as an enumeration of express specifications, but rather as an outline of the more general attributes of the…
2Cases cited6 opinions
- Hecht v. MalleySupreme Court of the United States · 1924
- Burk-Waggoner Oil Assn. v. HopkinsSupreme Court of the United States · 1925
- Crocker v. MalleySupreme Court of the United States · 1919
- E. A. Landreth Co. v. CommissionerUnited States Board of Tax Appeals · 1929
- Van Cleave Trust v. CommissionerUnited States Board of Tax Appeals · 1929
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