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HELVERING v. COMBS

No. 238.

296 U.S. 365 (1935)

56 S.Ct. 287

80 L.Ed. 275

HELVERING, COMMISSIONER OF INTERNAL REVENUE, v. COMBS ET AL., TRUSTEES.

Supreme Court of United States.

Decided December 16, 1935.

Attorney(s) appearing for the Case

Assistant Attorney General Morris, with whom Solicitor General Reed, Assistant Attorney General Wideman, and Miss Helen R. Carloss were on the brief, for petitioner.

Mr. Dana Latham, with whom Mr. Melvin D. Wilson was on the brief, for respondents.

MR. CHIEF JUSTICE HUGHES delivered the opinion of the Court.

The trustees of E.E. Combs Well No. 2 contested the ruling of the Commissioner of Internal Revenue that the taxpayer was taxable as an association, and not as a trust, on its income for the years 1925 and 1926. The Board of Tax Appeals sustained their contention and the Circuit Court of Appeals affirmed the order of the Board. 76 F.2d 682. A writ of certiorari was issued...

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