BW Jones Trust v. Commissioner of Internal Revenue

PARKER, Circuit Judge.

These are petitions to review a decision of the Board of Tax Appeals, now the Tax Court of the United States. There are five cases which were heard together before the Board and before this Court. The question involved is whether alien trusts are taxable upon capital gain derived from the sales of their securities within the United States under the Revenue Acts of 1936 and 1938, or whether they are exempt from such taxation because falling within the provision of section 211 of those acts. The Board held that the trusts were not within the provisions of section 211,…