Fidelity-Philadelphia Trust Co. v. Commissioner of Internal Revenue

Third Circuit

Fidelity-Philadelphia Trust Co. v. Commissioner of Internal Revenue

147 F.2d 290, 33 A.F.T.R. (P-H) 667, 1945 U.S. App. LEXIS 4359

Court of Appeals for the Third Circuit·Decided February 14, 1945·No. Nos. 8747, 8748·Published

Opinion

PER CURIAM.

The decision of the Tax Court, 3 T.C. 670, as against the trustee is affirmed on authority of Baur v. Commissioner, 3 Cir., 145 F.2d 338; Fidelity Trust Co. v. Commissioner, 3 Cir., 141 F.2d 54. We think, also, that as against the beneficiary of the trust it should be affirmed. See Commissioner v. Hart, 3 Cir., 106 F.2d 269, 271. It is not necessary to discuss the latter [291]*291proposition at length, since the judgment against the trustee renders the judgment against the beneficiary unimportant in this case.

Affirmed.

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PER CURIAM.

The decision of the Tax Court, 3 T.C. 670, as against the trustee is affirmed on authority of Baur v. Commissioner, 3 Cir., 145 F.2d 338; Fidelity Trust Co. v. Commissioner, 3 Cir., 141 F.2d 54. We think, also, that as against the beneficiary of the trust it should be affirmed. See Commissioner v. Hart, 3 Cir., 106 F.2d 269, 271. It is not necessary to discuss the latter [291]*291proposition at length, since the judgment against the trustee renders the judgment against the beneficiary unimportant in this case.

Affirmed.

Fidelity-Philadelphia Trust Co. v. Commissioner of Internal Revenue, 147 F.2d 290, 33 A.F.T.R. (P-H) 667, 1945 U.S. App. LEXIS 4359 (3d Cir. 1945).

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