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HELVERING v. HALLOCK

No. 110.

309 U.S. 106 (1940)

HELVERING, COMMISSIONER OF INTERNAL REVENUE, v. HALLOCK ET AL., TRUSTEES.

Supreme Court of United States.

Decided January 29, 1940.

Attorney(s) appearing for the Case

Mr. Arnold Raum, with whom Solicitor General Jackson, Assistant Attorney General Clark, and Messrs. Sewall Key and Lee A. Jackson were on the brief, for petitioners in Nos. 110-112, 183, and respondent in No. 399.

Messrs. Walker H. Nye and Ashley M. Van Duzer, with whom Mr. W.B. Stewart was on the brief, for respondents in Nos. 110 and 111. Mr. W.H. Annat submitted for respondent in No. 112. Mr. William R. Spofford, with whom Mr. George V. Strong was on the brief (Mr. Harold D. Saylor entered an appearance), for respondent in No. 183.

Messrs. J. Gilmer Korner, Jr. and David S. Day for petitioners in No. 399.

By leave of Court, Mr. Blatchford Downing, as amicus curiae, filed a brief in Nos. 111 and 183, urging affirmance.

MR. JUSTICE FRANKFURTER delivered the opinion of the Court.

These cases raise the same question, namely, whether transfers of property inter vivos made in trust, the particulars of which will later appear, are within the provisions of § 302 (c) of the Revenue Act of 1926.1 They were heard in succession and may be decided together. In each case the Commissioner of Internal Revenue included...

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