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168 F.2d 994

Docket No. 10508.

Green v. Commissioner

Sixth Circuit Court of Appeals

Decided June 4, 1948.

Sixth Circuit Court of Appeals · decided 1948-06-04

2 counsel of record

Relies on Helvering v. Clifford · Miller v. Commissioner of Internal Revenue · Shapero v. Commissioner

Good law ✅— No negative treatment on recordhow we know

Opinion by (per_curiam) · Decided 1948-06-04

How this case has been cited

Cited by 17 later decisions — most recently January 2001

3 federal appellate ·

1001948195019601970198019902000decided

Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.

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¶1*995Raphael M. O’Hara and Benjamin E. Jaffe, both of Detroit, Mich, for petitioner.

¶2Charles Oliphant, J. P. Wenchel, and Sewall Key, all of Washington, D. C., for respondent.

¶3Before HICKS, ALLEN and MARTIN, Circuit Judges.

¶4PER CURIAM.

¶5This case came on to be heard on the record and briefs and oral argument of counsel.

¶6And it appearing that the petitioner created two trusts for the benefit of his wife and minor son respectively, under which, as settlor-trustee, petitioner retained broad managerial powers ov.er the trust, including the right to deal with himself as an individual with respect to the trust properties, which right he exercised extensively;

¶7And it appearing that the decision of the Tax Court holding the petitioner taxable as an individual on the income of such trusts is correct; Helvering v. Clifford, 309 U.S. 331, 60 S.Ct. 554, 84 L.Ed. 788; Miller v. Commissioner, 6 Cir., 147 F.2d 189, 193; Shapero v. Commissioner, 6 Cir., 165 F.2d 811, 813, 814;

¶8And no reversible error appearing in the record:

¶9It is ordered that the decision of the Tax Court be, and it hereby is affirmed.

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