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HECHT v. MALLEY

Nos. 99, 100, 101, 119.

265 U.S. 144 (1924)

44 S.Ct. 462

68 L.Ed. 949

HECHT ET AL., TRUSTEES, v. MALLEY, FORMER COLLECTOR OF INTERNAL REVENUE. HOWARD ET AL., TRUSTEES, v. MALLEY, FORMER COLLECTOR OF INTERNAL REVENUE. HOWARD ET AL., TRUSTEES, v. CASEY, FORMER ACTING COLLECTOR OF INTERNAL REVENUE. CROCKER ET AL., TRUSTEES, v. MALLEY, FORMER COLLECTOR OF INTERNAL REVENUE.

Supreme Court of United States.

Decided May 12, 1924.

Attorney(s) appearing for the Case

Mr. Edward F. McClennen, with whom Mr. William H. Dunbar and Mr. Allison L. Newton were on the brief, for petitioners in Nos. 99, 100 and 101.

Mr. Alfred A. Wheat, Special Assistant to the Attorney General, with whom Mr. Solicitor General Beck was on the briefs, for respondents.

Mr. Harrison M. Davis, with whom Mr. Felix Rackemann was on the brief, for petitioners in No. 119.

MR. JUSTICE SANFORD delivered the opinion of the Court.

These four cases, which were heard together, involve the question whether the trustees of three "Massachusetts Trusts" are subject to the special excise taxes imposed upon certain "associations" by the Revenue Act of 1916 (39 Stat. 756, c. 463), and the Revenue Act of 19181 (40 Stat. 1057, c. 18), based upon the value of their capital stock...

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