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U.S. Court of Appeals for the Third Circuit, 1945

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

Fidelity-Philadelphia Trust Co. v. Commissioner of Internal Revenue
U.S. Court of Appeals for the Third Circuit · Decided February 14, 1945
147 F.2d 290; 33 A.F.T.R. (P-H) 667; 1945 U.S. App. LEXIS 4359 (Federal Reporter, Second Series)

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

Opinion of the Court

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 *291proposition at length, since the judgment against the trustee renders the judgment against the beneficiary unimportant in this case.

Affirmed.

Case-law data current through December 31, 2025. Source: CourtListener bulk data.

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