Legal Opinion

Crane v. Commissioner

United States Tax Court

Decided November 17, 1967No. Docket Nos. 4784-65, 4785-65PublishedCited by 11 opinions

Held: In determining when and what gifts were made -- 1. When Donald established savings accounts in the name of himself and one of his children, he remained the owner of the funds in the account; 2. When Donald established savings accounts in the name of Dorothy and one of their children, Dorothy and the child each acquired ownership of one-half of the account; 3. When Donald purchased real estate taking title in himself and Dorothy and used the funds in the accounts in the…

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Held: In determining when and what gifts were made -- 1. When Donald established savings accounts in the name of himself and one of his children, he remained the owner of the funds in the account; 2. When Donald established savings accounts in the name of Dorothy and one of their children, Dorothy and the child each acquired ownership of one-half of the account; 3. When Donald purchased real estate taking title in himself and Dorothy and used the funds in the accounts in the name of Dorothy and the children to provide part of the purchase price, the property was not held in a constructive or…

1Opinion of the Court

Simpson, Judge:

The respondent determined a deficiency in gift tax for the petitioner Donald V. Crane of $258.48 for the calendar year 1954 and an addition to the tax under section 6651(a) of the Internal Revenue Code of 19541 of $64.62. By amended answer, the respondent increased for 1954 the deficiency for Donald Y. Crane to the total amount of $398.15 and the addition to the tax to the total amount of $99.54. For the calendar year 1959, the respondent determined deficiencies in gift tax for the petitioner Donald Y. Crane of $16,290.47 and for the petitioner Dorothy Y. Crane of $10,695.

The…

2Cases cited32 opinions

  1. Nebbia v. New YorkSupreme Court of the United States · 1934
  2. Estate of Sanford v. CommissionerSupreme Court of the United States · 1939
  3. Choate v. TrappSupreme Court of the United States · 1912
  4. Burnet v. GuggenheimSupreme Court of the United States · 1933
  5. Olcott v. BynumSupreme Court of the United States · 1873

27 more not listed; retrieve them via the Exa API.

3Cited by11 opinions

  1. Ward v. CommissionerUnited States Tax Court · 1986
  2. Friedman v. CommissionerUnited States Tax Court · 1968
  3. Estate of Bennett v. CommissionerUnited States Tax Court · 1989
  4. Greenway v. CommissionerUnited States Tax Court · 1987
  5. Alvarez v. CommissionerUnited States Tax Court · 1987

6 more not listed; retrieve them via the Exa API.

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