(DOWNLOAD) "Guggenheim v. Helvering" by United States Court of Appeals for the Second Circuit ~ eBook PDF Kindle ePub Free
eBook details
- Title: Guggenheim v. Helvering
- Author : United States Court of Appeals for the Second Circuit
- Release Date : January 05, 1941
- Genre: Law,Books,Professional & Technical,
- Pages : * pages
- Size : 62 KB
Description
This appeal is from an order of the Board of Tax Appeals assessing a deficiency in the estate tax due from the petitioner, as executrix of Daniel Guggenheim; the questions rasised are of two kinds: (1) The proper value of items concededly includable in the gross estate; (2) whether certain items should be included at all. The first and most important of these is the proper value of the decedents interest in what is described as the "Old Firm." The other questions are (1) the value of his interest in the "New Firm"; (2) the inclusion in his estate of some collateral held by the "Old Firm" against his obligations; and (3) the inclusion of the corpus of a trust fund.The Board made very elaborate findings of fact and wrote a long and careful opinion (39 B.T.A. 251); later supplemented by another, confined to the frust estate (40 B.T.A. 181). We shall assume familiarity with the facts as there stated and shall restate them only so far as is necessary to make the discussion intelligible.