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Porter Vs. Commissioner
Cites for this judgment
- US Supreme Court
- Mar 13, 1933
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U.S. 436 (1933) U.S. Supreme Court Porter v. CommissionerSearch
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U.S. 436 (1933) Porter v. CommissionerSearch
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F.2d 673. Its decision being in conflict with that of the Circuit Court of Appeals for the First Circuit in Brady v. HamSearch
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F.2d 454, and that of the Court of Appeals of the District of Columbia in Cover v. BurnetSearch
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of this case, may be deemed the substantial equivalent of, a general power of appointment by will. Cf. United States v. FieldSearch
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Clapp v. IngrahamSearch
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property in which the decedent then held no interest or power of enjoyment must be excluded. They rely on Reinecke v. NorthernSearch
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As the title was put beyond his control, we held these transfers not taxable. And petitioners assume, as held in White v. ErskineSearch
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be said that, if it stood alone, (a) would extend to the transfers brought into the gross estate by (d). United States v. FieldSearch
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Tyler v. UnitedSearch
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transfers in question would be to measure decedent's tax by property belonging to others, a thing condemned in Heiner v. DonnanSearch
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U. S. 312 , and Hoeper v. TaxSearch
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were fully consummated prior to the enactment of subdivision (d), and therefore would be confiscatory under Nichols v. CoolidgeSearch
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U. S. 531 , and Heiner v. DonnanSearch
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power of revocation. It is true that the power reserved was not absolute, as in the transfer considered in Burnet v. GuggenheimSearch
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net estate. Thus was reached what it reasonably might deem a substitute for testamentary disposition. United States v. WellsSearch
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U. S. 116 . There is no doubt as to the power of Congress so to do. Page 288 U. S. 445 Reinecke v. NorthernSearch
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Chase National Bank v. UnitedSearch
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States, supra. Tyler v. UnitedSearch
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Klein v. UnitedSearch
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U.S. Supreme Court Porter v. CommissionerSearch
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Brady v. HamSearch
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Cover v. BurnetSearch
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Cf. United States v. FieldSearch
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Reinecke v. NorthernSearch
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White v. ErskineSearch
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and Hoeper v. TaxSearch
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and Heiner v. DonnanSearch
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United States v. WellsSearch
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