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Harrison Vs. Schaffner
Cites for this judgment
- US Supreme Court
- Mar 31, 1941
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U.S. 579 (1941) U.S. Supreme Court Harrison v. SchaffnerSearch
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U.S. 579 (1941) Harrison v. SchaffnerSearch
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certiorari, 311 U.S. 638, to resolve an alleged conflict in principle of the decision below with those in Lucas v. EarlSearch
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U. S. 136 , and Helvering v. CliffordSearch
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U. S. 331 . Since granting certiorari, we have held, following the reasoning of Lucas v. EarlSearch
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taxable income quite as much as if he had collected the income and paid it over to the object of his bounty. Helvering v. HorstSearch
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and is thus the recipient of income from his own property which is taxable to him, rather than to the donor. See Blair v. CommissionerSearch
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but rather on the import and reasonable construction of the taxing act. Lucas v. EarlSearch
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the actual command over the income which is taxed and the actual benefit for which the tax is paid. See Corliss v. BowersSearch
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and held in consequence that the income thereafter paid to the donee was taxable to him and not the donor. Blair v. CommissionerSearch
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of a short-term trust created for the benefit of the donee is nevertheless income taxable to the donor. Helvering v. CliffordSearch
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Act is concerned, between a gift of income in a specified amount by the creation of a trust for a year, see Hormel v. HelveringSearch
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difficulty in those fields of the law where differences in degree produce ultimate differences in kind. See Irwin v. GavitSearch
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of income from property of which the donor remains the owner for all substantial and practical purposes. Cf. Helvering v. CliffordSearch
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U.S. Supreme Court Harrison v. SchaffnerSearch
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and Helvering v. CliffordSearch
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of Lucas v. EarlSearch
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See Blair v. CommissionerSearch
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See Corliss v. BowersSearch
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Blair v. CommissionerSearch
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See Irwin v. GavitSearch
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Cf. Helvering v. CliffordSearch
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