| United States. Court of Claims - 1947 - 828 pages
...had no alternative. "* * * taxation is not so much concerned with the refinements of title as it is with actual command over the property taxed — the actual benefit for which the tax is paid." Corliss v. Bowers, 281 US 376, 378. Here the decedent had no command over the payment made by the company... | |
| United States. Court of Claims, Audrey Bernhardt - 1962 - 784 pages
...capital gains In question. ' "[TJniatlon is not BO much concerned with the refinements of title as It is with actual command over the property taxed — the actual benefit for which the tax U paid." Corlisi \. Bovteri, 281 US 376, 377-378 (1930). See also Burnet v. WeUf, 289 US 670, 677-878... | |
| United States. Board of Tax Appeals - 1933 - 1616 pages
...appropriate it does not matter whether the permission is given by assent or by failure to express dissent. The Income that is subject to a man's unfettered command and that he is free to enjoy at his own option may be taxed to him as his income* whether he sees fit to enjoy it or not * * * See also Grace... | |
| United States. Board of Tax Appeals - 1934 - 1512 pages
...said repeatedly, " Taxation is not so much concerned with the refinements of title as it is with the actual command over the property taxed — the actual benefit for which the tax is paid." Corliss v. Bowers, supra, at page 378; Tyler v. United States, 281 US 497; Burnet v. Guggenheim, supra;... | |
| United States. Congress. House. Committee on Ways and Means - 1934 - 338 pages
...from that case : But taxation is not so much concerned with the refinements of title as it is with the actual command over the property taxed, the actual benefit for which the tax is paid. Refinements of title have at times supplied the rule when the question lias been one of construction... | |
| United States. Board of Tax Appeals - 1935 - 1394 pages
...declare that, where taxing acts are challenged, we look not to the refinements ol! title but to the actual command over the property taxed — the actual benefit for which the tax is pnid. Corliss v. Bowers, supra, 281 US at page 378, 50 S. Cf. 336, 74 L. Ed. 916; Tyler v. United States,... | |
| United States. Congress. Internal Revenue Taxation Joint Committee - 1936 - 144 pages
...upholding the right of the Government to tax the income from a revocable trust to the grantor, said : The income that is subject to a man's unfettered command and that he is free to enjoy at his own option may be taxed to him as his income whether he sees fit to enjoy it or not. (c) Irrevocable trusts.... | |
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