WILLIS, EXECUTRIX,
v.
PENNSYLVANIA RAILROAD CO.

U.S. | 1941-11-10
No. 686
314 U.S. 684 Supreme Court of the United States (1941) Positive Treatment
Cited by 10 cases

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  • …d gift to the wife of the insured, and therefore not subject to the estate tax. This Court, however, did not, in that case, apply the Clifford doctrine to the estate tax. But see Richardson v. Commissioner, 121 F. 2d 1 (C. A. 2d Cir.), cert. denied, 314 U. S. 684, where it was held that, under the Clifford case, a trustee, with a broad power of revocation which might at any time be exercised for his own benefit, was himself liable for the income tax on the income of the trust. See also, Bunting v. Commission…
  • Commissioner of Internal Revenue v. Newman, 159 F.2d 848 (2d Cir. 1947)
    …ppropriate either the principal or the income of the trusts to himself, the income is taxable to him. Corliss v. Bowers, 281 U.S. 376, 50 S.Ct. 336, 74 L.Ed. 916; Richardson v. Commissioner of Internal Revenue, 2 Cir., 121 F. 2d 1, certiorari denied 314 U.S. 684, 62 S.Ct. 188, 86 L.Ed. 584. The Tax Court, six judges dissenting, determined that it did not, 5 T.C. 603, and the Commissioner has petitioned this court for review. Whether the grant gives respondent such power depends upon the intention of the g…
  • Arguelles v. U. S. Bulk Carriers, Inc., 408 F.2d 1065 (4th Cir. 1969)
    …agreement was introduced in evidence as Joint Exhibit No. 1. . A well documented discussion by Judge Prank concerning the historical protec [*1070] tion of seamen is found in Hume v. Moore-McCormack Lines, 121 F. 2d 336 (2 Cir. 1941), cert. denied, 314 U.S. 684, 62 S.Ct. 188, 86 L.Ed. 547. . Collie v. Fergusson, 281 U.S. 52, 56, 50 S.Ct. 189, 191, 74 L.Ed. 696 (1930). Involved was 46 U.S.C. § 596. Insolvency of the owner and arrest of the vessel were held to be “sufficient cause” for delayed payment of wa…

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