HOEY, COLLECTOR OF INTERNAL REVENUE,

v.

HESSLEIN

Citator

Cited By

• Est. of Sanford v. Commissioner of Internal Revenue, 308 U.S. 39 (U.S. 1939)
  …ard of Tax Appeals sustaining the tax was affirmed by the Court of Appeals for the Third Circuit, 103 F. 2d 81, which followed the decision of the Court of Appeals for the Second Circuit in Hesslein v. Hoey, supra, in which we had denied certiorari, 302 U. S. 756. In the Hesslein case, as in the Humphreys case now [*42] before us, a gift in trust with the reservation of a power in the donor to alter the disposition of the property in any way not beneficial to himself, was held to be incomplete and not subjec…
• In re Tyler's Est. Fidelity-Philadelphia Tr. Co. v. Commissioner of Internal Revenue, 109 F.2d 421 (3d Cir. 1940)
  …t of the decedent’s gross estate for estate tax purposes, the settlor at the time of his death having possessed the power to alter or amend the trust. Sanford’s Estate v. Commissioner, supra; Hesslein v. Hoey, 2 Cir., 91 F. 2d 954, certiorari denied 302 U.S. 756, 58 S.Ct. 284, 82 L.Ed. 585. The decision of the Board is affirmed.…
• Commissioner of Internal Revenue v. Hart, 106 F.2d 269 (3d Cir. 1939)
  …ate problem in the construction of the same words (involving gifts in trust with reserved power to alter but not revest in the donor) has'been decided favorably to the taxpayer in the Second Circuit, Hesslein v. Hoey, 91 F. 2d 954, certiorari denied 302 U.S. 756, 58 S.Ct. 284, 82 L.Ed. 585. The reasoning of this case has recently been approved and applied (under the circumstances, adversely tó the taxpayer) in our own Circuit, Sanford v. Commissioner, 103 F. 2d 81, decided March 25, 1939, certiorari granted…