BOYDEN
v.
UNITED STATES

U.S. | 1969-10-20
No. 244
Mr. Justice Marshall took no part in the consideration or decision of this petition.
396 U.S. 881 Supreme Court of the United States (1969) Positive Treatment
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  • Estelle Morris Trs. v. Commissioner OF Internal Revenue, 427 F.2d 1361 (9th Cir. 1970)
    …e trusts, tacitly or covertly.1 Furthermore, federal courts have not been deterred from realistic interpretations of taxpayer entities to prevent tax avoidance, even though Congress had not yet acted to check abuses. United States v. Grace’s Estate, 396 U.S. 881, 90 S.Ct. 147, 24 L.Ed.2d 141 (1969); Higgins v. Smith, 308 U.S. 473, 60 S.Ct. 355, 84 L.Ed. 406 (1938). In this regard, I agree with the Tax Court dissent that the “maintenance of 10 sets of records (not 20) was but a meaningless formality * * * wi…

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