Philadelphia-Detroit Lines, Inc. v. United States

How later courts describe this case

• where the proposition is stated, although the parties were held to have waived any objection and were not permitted to attack the judgment collaterally
• “State law creates legal interests and rights. The federal revenue acts designate what interests or rights, so created, shall be taxed.”
• state law determines the nature of the legal interest the taxpayer had in the property or income sought
• analyzing meaning of “general power of appointment” for federal estate tax purposes; recognizing that “[s]tate law creates legal interests and rights,” while “federal revenue acts designate what interests or rights, so created, shall be taxed”