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United States v. Manufacturers Nat’l Bank, 363 U.S. 194 (1960)
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General SummaryThis case is from a collection containing the full text of over 16,000 Supreme Court cases from 1793 to the present. The body of Supreme Court decisions are, effectively, the final interpretation of the Constitution. Only an amendment to the Constitution can permanently overturn an interpretation and this has happened only four times in American history.
United States v. Manufacturers Nat’l Bank, 363 U.S. 194 (1960)
United States v. Manufacturers National Bank of Detroit No. 350 Argued March 31, 1960 Decided June 13, 1960 363 U.S. 194
APPEAL FROM THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF MICHIGAN
Syllabus
In 1936, respondent’s decedent divested himself of his rights in certain insurance policies on his own life by assigning them to his wife, but he continued to pay the premiums on them until he died in 1954. The Internal Revenue Service determined that, under § 811(g)(2)(A) of the Internal Revenue Code of 1939, the portion of the proceeds attributable to premiums paid by the insured after January 10, 1941, should be included in his estate for the purposes of the federal estate tax.
Held: as thus applied, § 811 (g)(2)(A) is constitutional. Pp. 194-201.
(a) The tax is not a direct tax on property which Congress cannot exact without apportionment among the States. Pp. 197-200.
(b) The tax is not retroactive, and does not violate the Due Process Clause of the Fifth Amendment. Pp. 200-201.
175 F. Supp. 291 reversed.
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Chicago:
U.S. Supreme Court, "Syllabus," United States v. Manufacturers Nat’l Bank, 363 U.S. 194 (1960) in 363 U.S. 194 Original Sources, accessed July 1, 2025, http://www.originalsources.com/Document.aspx?DocID=HLAJ5GYP5CCG6WI.
MLA:
U.S. Supreme Court. "Syllabus." United States v. Manufacturers Nat’l Bank, 363 U.S. 194 (1960), in 363 U.S. 194, Original Sources. 1 Jul. 2025. http://www.originalsources.com/Document.aspx?DocID=HLAJ5GYP5CCG6WI.
Harvard:
U.S. Supreme Court, 'Syllabus' in United States v. Manufacturers Nat’l Bank, 363 U.S. 194 (1960). cited in 1960, 363 U.S. 194. Original Sources, retrieved 1 July 2025, from http://www.originalsources.com/Document.aspx?DocID=HLAJ5GYP5CCG6WI.
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