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Bogardus Vs. Commissioner
Cites for this judgment
- US Supreme Court
- Nov 08, 1937
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U.S. 34 (1937) U.S. Supreme Court Bogardus v. CommissionerSearch
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U.S. 34 (1937) Bogardus v. CommissionerSearch
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under (b)(3) of the same section. Old Colony Trust Co. v. CommissionerSearch
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of other courts of appeal upon the question under review are conflicting. Upon the one side, the First Circuit, Walker v. CommissionerSearch
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F.2d 61, Judge Morton dissenting, the Fourth, Hall v. CommissionerSearch
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F.2d 441, and the Fifth, Simpkinson v. CommissionerSearch
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the other side, more or less definitely to the contrary, are to be found the decisions of the Third Circuit, Jones v. CommissionerSearch
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Cunningham v. CommissionerSearch
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F.2d 205, the Sixth, Lunsford v. CommissionerSearch
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F.2d 740, and the Ninth, Blair v. RosseterSearch
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Helvering v. Tex-PennSearch
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and evidentiary facts. The ultimate determination therefore should be overturned, under the doctrine of Helvering v. RankinSearch
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be both a gift and a payment of compensation. The court below went on to say that decisions like Old Colony Trust Co. v. CommissionerSearch
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employees, there might be ground for the inference that they were payments of additional compensation. Compare Noel v. ParrottSearch
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We agree with this dissenting opinion of Judge Swan, and the dissenting opinion of Judge Morton in Walker v. CommissionerSearch
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the light of the intention. A similar question was before the Court of Appeals for the District of Columbia in Levey v. HelveringSearch
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S. 44 this case, was misdescribed in the resolutions to carry the decision and intention into effect. In Rogers v. HillSearch
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the less a gift because inspired by gratitude for the past faithful service of the recipient. Compare Hobart's Adm'r v. VailSearch
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is taxable as income, though made without consideration, and hence for many purposes a gift. Old Colony Trust Co. v. CommissionerSearch
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of any tax, is to work havoc with the law. A large body of decisions, whose provenance is Old Colony Trust Co. v. CommissionerSearch
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would be annulled by such a test. See e.g., Weagant v. BowersSearch
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Fisher v. CommissionerSearch
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Bass v. HawleySearch
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United States v. McCormickSearch
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Botchford v. CommissionerSearch
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Schumacher v. UnitedSearch
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enough. If there was opportunity for opposing inferences, the judgment of the Board controls. Elmhurst Cemetery Co. v. CommissionerSearch
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U.S. Supreme Court Bogardus v. CommissionerSearch
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the First Circuit, Walker v. CommissionerSearch
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the Fourth, Hall v. CommissionerSearch
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and the Fifth, Simpkinson v. CommissionerSearch
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of the Third Circuit, Jones v. CommissionerSearch
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the Sixth, Lunsford v. CommissionerSearch
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and the Ninth, Blair v. RosseterSearch
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of Helvering v. RankinSearch
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Compare Noel v. ParrottSearch
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Walker v. CommissionerSearch
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Levey v. HelveringSearch
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In Rogers v. HillSearch
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Compare Hobart's Adm'r v. VailSearch
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Weagant v. BowersSearch
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Old Colony Trust Co. v. CommissionerSearch
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