GUARANTY TRUST CO. v. COMM'R

No. 301.

303 U.S. 493 (1938)

GUARANTY TRUST CO., EXECUTOR, v. COMMISSIONER OF INTERNAL REVENUE.

Supreme Court of United States.

Decided March 28, 1938.


Attorney(s) appearing for the Case

Mr. Montgomery B. Angell, with whom Messrs. John W. Davis and Weston Vernon, Jr. were on the brief, for petitioner.

Mr. Edward J. Ennis, with whom Solicitor General Reed, Assistant Attorney General Morris, and Messrs. Sewall Key and A.F. Prescott were on the brief, for respondent.


MR. JUSTICE STONE delivered the opinion of the Court.

Whether a deceased partner's taxable income for the calendar year 1933 includes his share of partnership profits from the beginning of the partnership fiscal year on August 1, 1933, to the date of his death in the same year, in addition to his share of the partnership profits for its fiscal year ending July 31, is the question for decision.

Petitioner's testator, who died December 16, 1933, was a member...

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