Supreme Court of the United States, 1934

Reynolds v. Cooper

Supreme Court of the United States · Decided January 15, 1934 · McReynolds, Brandeis, Stone, Cardozo, Falk

291 U.S. 192; 54 S. Ct. 356; 78 L. Ed. 725; 1934 U.S. LEXIS 984; 1 C.B. 250; 13 A.F.T.R. (P-H) 851; 4 U.S. Tax Cas. (CCH) 1222 (United States Reports)

Counsel

Mr. Erwin N. Griswold, with whom Solicitor General Biggs, Mr. Sewall Key, and Miss Helen R. Carloss were on the brief, for petitioner., Mr. N. E. Corthell, with whom Mr. A. W. McCollough was on the brief, for respondents.

Cases that cite this one

8 later published cases cite this decision.

Jud Plumbing & Heating v. Commissioner (United States Tax Court 1945)
Maimonides Medical Center v. United States (District Court, E.D. New York 2014)
Garwood Irrigation Company v. Commissioner (United States Tax Court 2006)
Dana Distributors, Inc. v. Commissioner (United States Tax Court 1988)
Water Quality Association Employees' Benefit Corporation v. United States (7th Cir. 1986)
Jud Plumbing & Heating, Inc. v. Commissioner (United States Tax Court 1945)
Inland Development Co. v. Commissioner of Int. Rev. (10th Cir. 1941)
Hurley v. United States (United States District Court, Oklahoma Northern 1935)

This list shows which later cases cite this one. It does not say how they treated it, and no review of that has been done. Not a substitute for Shepard’s or KeyCite — verify before relying.

Opinion

Mr. Justice McReynolds

delivered the opinion of the Court.

In each of these causes a beneficiary received from trustees royalties arising from a lease of oil and gas lands. in Wyoming. Taxes were exacted upon the full amounts so received. Separate ■ suits were brought to recover proper allowances for depletion. The respondents prevailed in both of the courts below. Here the causes were heard together.

*193 The Solicitor General says — “ The question is identical with that raised in Helvering v. Falk, No. 225, October Term, 1933, and the argument made in the Government’s brief in that case is likewise applicable here. . . . There is therefore substantially no difference between the position of the beneficiaries in this case and the Falk case.”

The judgments below are affirmed upon authority of Helvering v. Falk, decided this day, ante, p. 183.

Affirmed.

Mr. Justice Brandeis, Mr. Justice Stone, and Mr. Justice Cardozo think that these cases are to be distinguished from No. 225, Helvering y. Falk, just decided, because of the nature of the duties imposed upon the trustees, and of the remainder interest granted to the beneficiaries by the trust instrument presently involved, and accordingly concur in the result.

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