DONEGHY ET AL., RESIDUARY TRUSTEES,

v.

ALEXANDER, FORMERLY COLLECTOR OF INTERNAL REVENUE; AND DONEGHY ET AL., RESIDUARY TRUSTEES, V. JONES, COLLECTOR OF INTERNAL REVENUE

Citator

Cited By

• United States v. O'Malley, 383 U.S. 627 (U.S. 1966)
  …predecessors are Commissioner v. Hager’s Estate, 173 F. 2d 613, petition for cert. dismissed, 337 U. S. 937; Estate of Showers v. Commissioner, 14 T. C. 902; Estate of Guggenheim v. Commissioner, 40 B. T. A. 181, aff’d, 117 F. 2d 469, cert. denied, 314 U. S. 621. The Court of Appeals in McDermott’s Estate was clearly wrong in saying that the transfer there involved was as complete as was the transfer in Gidwitz. In Gidwitz the transfer was in trust and the grantor was one of the trustees but there was a sp…
• Commissioner OF Internal Revenue v. Murray Thompson, 222 F.2d 893 (3d Cir. 1955)
  …on for abdicating the judicial function, which, in the administration of justice, is frequently called upon to appraise intangibles. Guggenheim v. Helvering, 2 Cir., 1941, 117 F. 2d 469, 474, certiorari denied Guggenheim’s Estate v. C. I. R., 1941, 314 U.S. 621, 62 S.Ct. 66, 86 L.Ed. 499; Colonial Fabrics v. Commissioner of Internal Revenue, 2 Cir., 1953, 202 F. 2d 105, 107. Nor is it essential “ * * * there be testimony of the specific figure fixed by the Tax Court.” Burford-Toothaker Tractor Co. v. Commi…
• Union Tr. Co. of Pittsburgh v. Driscoll, 138 F.2d 152 (3d Cir. 1943)
  …mmissioner of Internal Revenue, 1 Cir., 1941, 118 F. 2d 254, 139 A.L.R. 508, certiorari denied 1941, 314 U.S. 636, 62 S.Ct. 70, 86 L.Ed. 511; Guggenheim v. Helvering, 2 Cir., 1941, 117 F. 2d 469, certiorari denied Guggenheim’s Estate v. Com’r, 1941, 314 U.S. 621, 62 S.Ct. 66, 86 L.Ed. 499. If we had here a stranger as trustee, with the power to alter the interests of the named beneficiaries within the group reserved to the settlor, there would be no question that the trust corpus was within the gross estate…