Legal Opinion
Commissioner of Internal Revenue v. North American Bond Trust
Court of Appeals for the Second Circuit
Decided August 14, 1941No. 237PublishedCited by 17 opinions
1Opinion of the Court
L. HAND, Circuit Judge.
I distinguish the case at bar from Commissioner v. Chase National Bank, 122 F.2d 540 handed down at the same time, because here the “Depositor” had it in his power in effect to change the investment of certificate holders at his discretion, as I shall try to show. In Commissioner v. Chase National Bank, supra, each “Unit” consisted of sixteen shares in each of thirty specified companies; and each later “Unit” had to be made up of exactly that number of shares in each of those companies. Therefore, no matter how many “Units” were added, the investment of each certificate…
2Cases cited3 opinions
- Morrissey v. CommissionerSupreme Court of the United States · 1935
- A. A. Lewis & Co. v. CommissionerSupreme Court of the United States · 1937
- Commissioner of Internal Revenue v. Chase Nat. BankCourt of Appeals for the Second Circuit · 1941
3Cited by17 opinions
- Smith v. CommissionerUnited States Tax Court · 1959
- Principal Life Insurance Company and Subsidiaries v. United StatesUnited States Court of Federal Claims · 2014
- Pennsylvania Co. for Insurances on Lives & Granting Annuities v. United StatesCourt of Appeals for the Third Circuit · 1943
- Commissioner of Internal Rev. v. City Nat. Bank & T. Co.Court of Appeals for the Tenth Circuit · 1944
- Elm Street Realty Trust v. CommissionerUnited States Tax Court · 1981
12 more not listed; retrieve them via the Exa API.