Middlebrook v. Commissioner
United States Tax Court
Petitioner as of May 11, 1938, owned 455 shares of the 500 outstanding shares of stock of Metropolitan Buick Co. On July 12, 1938, he made a gift of 199 shares of stock to his wife and on March 8, 1939, he made a further gift of one share to her. The gifts were irrevocable and no condition of any kind was attached to them.
Read the full summary
Petitioner as of May 11, 1938, owned 455 shares of the 500 outstanding shares of stock of Metropolitan Buick Co. On July 12, 1938, he made a gift of 199 shares of stock to his wife and on March 8, 1939, he made a further gift of one share to her. The gifts were irrevocable and no condition of any kind was attached to them. On March 15, 1939, the corporation was dissolved and the petitioner, joined by his wife and the other remaining stockholder as the sole owners of the corporate assets, transferred them to a newly organized partnership composed of petitioner, his wife, and the other…
1Opinion of the Court
Joseph Middlebrook, Jr., Petitioner, v. Commissioner of Internal Revenue, Respondent
Middlebrook v. Commissioner
Docket No. 13879
United States Tax Court
13 T.C. 385; 1949 U.S. Tax Ct. LEXIS 84;
September 27, 1949, Promulgated
Decision will be entered under Rule 50.
Petitioner as of May 11, 1938, owned 455 shares of the 500 outstanding shares of stock of Metropolitan Buick Co. On July 12, 1938, he made a gift of 199 shares of stock to his wife and on March 8, 1939, he made a further gift of one share to her. The gifts were irrevocable and no condition of any kind was attached to them. On March 15,…
2Cases cited7 opinions
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
- Commissioner v. TowerSupreme Court of the United States · 1946
- Lusthaus v. CommissionerSupreme Court of the United States · 1946
- Reis v. CommissionerUnited States Tax Court · 1942
- Delchamps v. CommissionerUnited States Tax Court · 1949
2 more not listed; retrieve them via the Exa API.