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Commissioner Vs. Stern
Cites for this judgment
- US Supreme Court
- Jun 09, 1958
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U.S. 39 (1958) U.S. Supreme Court Commissioner v. SternSearch
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U.S. 39 (1958) Commissioner v. SternSearch
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Tyson v. CommissionerSearch
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is to be determined by state or federal law. Compare, e.g., Rowen v. CommissionerSearch
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F.2d 641, and Botz v. HelveringSearch
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F.2d 538, with United States v. BessSearch
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F.2d 675, and Stoumen v. CommissionerSearch
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T.C. 1014. This Court has expressly left the question open. Phillips v. CommissionerSearch
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a substantive liability, but provides merely a new procedure by which the Government may collect taxes. Phillips v. CommissionerSearch
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Hatch v. MoroscoSearch
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Liquidators of Exchange National Bank v. UnitedSearch
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Harwood v. EatonSearch
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Weil v. PageSearch
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Tooley v. CommissionerSearch
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the protection of private creditors, as in cases where the debtor had transferred his property to another. Phillips v. CommissionerSearch
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Pierce v. UnitedSearch
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Hospes v. NorthwesternSearch
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applicability of Kentucky law in favor of having the federal courts fashion governing rules. Cf. Clearfield Trust Co. v. UnitedSearch
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seeks to collect unpaid taxes from persons other than the defaulting taxpayer, have applied state statutes, Hutton v. CommissionerSearch
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Weil v. CommissionerSearch
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United States v. GoldblattSearch
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Botz v. HelveringSearch
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creditors, in cases where the debtor had transferred his property to another and been left insolvent. Cf. Pierce v. UnitedSearch
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courts must now apply state decisional law in defining state-created rights, obligations, and liabilities. Erie R. Co. v. TompkinsSearch
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that state law may not destroy a tax lien which has attached in the insured's lifetime. We held today in United States v. BessSearch
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The Court of Appeals in this case followed its own prior decision in Tyson v. CommissionerSearch
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is a transferee only to the extent of the cash surrender value existing at the time of the insured's death. Rowen v. CommissionerSearch
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The Tax Court, on the other hand, has held that the beneficiary is the transferee of the entire proceeds. Stoumen v. CommissionerSearch
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Rowen v. CommissionerSearch
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body of controlling rules which fairly implement the collection of government revenues. Cf. Clearfield Trust Co. v. UnitedSearch
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United States v. StandardSearch
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Priebe & Sons, Inc., v. UnitedSearch
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Textile Workers v. LincolnSearch
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liability Page 357 U. S. 50 despite the opposition of several Courts of Appeals. See, e.g., Muller v. CommissionerSearch
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Leary v. CommissionerSearch
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Bales v. CommissionerSearch
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Stoumen v. CommissionerSearch
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by those courts which have heretofore determined transferee liability on the basis of federal law. See, e.g., Pearlman v. CommissionerSearch
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Updike v. UnitedSearch
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the federal courts which may be traced back, in part at least, as far as the noted decision by Justice Story in Wood v. DrummerSearch
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not impose an unfair burden on transferees. Turning to the present case, I agree with the Court in United States v. BessSearch
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interests are thus established, their consequence for purposes of federal taxation is a matter of federal law. Watson v. CommissionerSearch
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Morgan v. CommissionerSearch
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U.S. Supreme Court Commissioner v. SternSearch
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and Botz v. HelveringSearch
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and Stoumen v. CommissionerSearch
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Phillips v. CommissionerSearch
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