ABRAHAM v. UNITED STATES

No. 18470.

406 F.2d 1259 (1969)

George G. ABRAHAM and Herbert Abraham, Trustees of the Abraham Trust, Plaintiffs-Appellants, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals Sixth Circuit.

February 13, 1969.


Attorney(s) appearing for the Case

Taylor Malone, Jr., Memphis, Tenn., for plaintiffs-appellants.

Lester B. Snyder, Dept. of Justice, Washington, D. C., for defendant-appellee; Mitchell Rogovin, Asst. Atty. Gen., Lee A. Jackson, William A. Friedlander, Marco S. Sonnenschein, Attys., Dept. of Justice, Washington, D. C., on brief; Thomas L. Robinson, U. S. Atty., Memphis, Tenn., of counsel.

Before WEICK, Chief Judge, and O'SULLIVAN and EDWARDS, Circuit Judges.


EDWARDS, Circuit Judge.

This case presents a single legal issue: Where a trust instrument provides the trust with the normal characteristics of a corporation and gives the trustees the normal powers necessary to conduct business, do these facts require that the trust be regarded as an "association" which is taxable like a corporation, even though its actual activities are consistent with those of a liquidating trust?1

Chief Judge...

Let's get started

Leagle.com

Welcome to the leading source of independent legal reporting
Sign on now to see your case.
Or view more than 10 million decisions and orders.

  • Updated daily.
  • Uncompromising quality.
  • Complete, Accurate, Current.

Listed below are the cases that are cited in this Featured Case. Click the citation to see the full text of the cited case. Citations are also linked in the body of the Featured Case.

Cited Cases

  • No Cases Found

Listed below are those cases in which this Featured Case is cited. Click on the case name to see the full text of the citing case.

Citing Cases