Opinion

Smith v. Commissioner

4 T.C. 573
1945 U.S. Tax Ct. LEXIS 250

Court: United States Tax Court
Filed: Jan 16, 1945
Status: Published
Author: Leechhillhaekonkernopper
On the bench: Smith,Disney,Opper
Cited by: 9 cases
Authority: More cited than 10.3%

The opinion

Leech, Hill, Haekon, Kern, and Opper, JJ., dissenting: We can not fairly distinguish the facts in either Louis Stockstrom, 3 T. C. 255 , or Joel E. Hall, 4 T. C. 506 , from those here. In addition, there are features of the conduct and operation of these trusts which are comparable to those leading to nonrecognition of the trusts in such earlier cases as Benjamin F. Woilman, 31 B. T. A. 37, and William C. Rands., 34 B. T. A. 1107, the true forerunners of the Clifford case. We accordingly dissent.

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