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Commissioner Vs. Estate of Bosch

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  • US Supreme Court
  • Jun 05, 1967

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67 entries 5 linked 62 unlinked
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  1. Heiner Vs. Mellon US Supreme Court · May 16, 1938
  2. Lyeth Vs. Hoey US Supreme Court · Dec 05, 1938
  3. Cities Service Oil Co. Vs. Dunlap US Supreme Court · Dec 04, 1939
  4. Fidelity Union Trust Co. Vs. Field US Supreme Court · Dec 09, 1940
  5. Burnet Vs. Harmel US Supreme Court · Nov 07, 1932
  6. Commissioner v. Estate
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  7. of Bosch - 387 U.S. 456 (1967) U.S. Supreme Court Commissioner v. Estate
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  8. of Bosch, 387 U.S. 456 (1967) Commissioner of Internal Revenue v. Estate
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  9. when the United States is not made a party to such proceeding. In No. 673, Commissioner of Internal Revenue v. Estate
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  10. to delve into the correctness of that state court decree. In No. 240, Second National Bank of New Haven, Executor v. United
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  11. by the determination made of such property interest by a state trial court. I (a) No. 673, Commissioner v. Estate
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  12. for the marital deduction. We do not agree, and reverse. (b) No. 240, Second National Bank of New Haven, Executor v. United
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  13. Ragan v. Merchants
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  14. General Box Co. v. United
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  15. The Tungus v. Scovgaard
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  16. In Freuler v. Helvering
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  17. Gallagher v. Smith
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  18. F.2d 218, 225. The opposite view is expressed in Faulkerson's Estate v. United
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  19. States, 301 F.2d 231. This view seems to approach that of Erie R. Co. v. Tompkins
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  20. is binding in such cases only when the judgment is the result of an adversary proceeding in the state court. Pierpont v. C.I
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  21. was not made a party to either of the state proceedings here and neither had the effect of res judicata, Freuler v. Helvering
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  22. within the section. Erie R. Co. v. Tompkins
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  23. Cohen v. Beneficial
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  24. King v. Order
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  25. where the highest court of the State has not spoken on the point. King v. Order
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  26. of Travelers, supra, at 333 U. S. 160 -161. And in West v. A.T
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  27. issue of state law should a fortiori not be controlling. This is but an application of the rule of Erie R. Co. v. Tompkins
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  28. of other courts of the State. In this respect, it may be said to be, in effect, sitting as a state court. Bernhardt v. Polygraphic
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  29. Together with No. 240, Second National Bank of New Haven, Executor v. United
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  30. Falkerson's Estate v. United
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  31. It may be claimed that Blair v. Commissioner
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  32. rights and when property rights rest on state law, as they do here. Since our 1938 decision in Erie R. Co. v. Tompkins
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  33. decisions, state administrative practice, for the state law that is to be applied. See, e.g., Cities Service Oil Co. v. Dunlap
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  34. Bernhardt v. Polygraphic
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  35. Court showing that the state law is other than announced by the lower court. See, e.g., Fidelity Union Trust Co. v. Field
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  36. West v. A.T
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  37. Six Companies of California v. Joint
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  38. Stoner v. New
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  39. York Life Ins. Co., 311 U. S. 464 . It is true that, in King v. Order
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  40. courts to take state law from state court decisions when federal tax consequences turned on state law. In Freuler v. Helvering
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  41. U.S. at 291 U. S. 45 . The issue of the effect of a state court determination came up again in Blair v. Commissioner
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  42. Id. 9-10. I would adhere to Freuler v. Helvering
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  43. supra, and Blair v. Commissioner
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  44. taxes. But there are some instances in which an adversary proceeding is impossible ( see, e.g., Estate of Darlington v. Commissioner
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  45. tax the taxpayer or his estate for benefits which he does not have under state law. This aspect is emphasized in Blair v. Commissioner
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  46. Government attempted to tax the taxpayer for income to which he had no right under state law. In Second National Bank v. United
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  47. Burnet v. Harmel
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  48. be resolved by reference to the principles of res judicata or collateral estoppel, see generally Cromwell v. County
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  49. state courts must be accepted as a part of the state law to which the Act gives force in federal courts, Erie R. Co. v. Tompkins
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  50. Note, The Competence of Federal Courts to Formulate Rules of Decision, 77 Harv.L.Rev. 1084. Compare, e.g., Morgan v. Commissioner
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