Brittingham v. Commissioner
United States Tax Court
Juan R. Brittingham, petitioner Robert's brother, placed $ 241,000 in the petitioner's bank account with instructions that Robert was to use these funds to purchase bonds for his mother. Respondent claimed these funds were gross income to the petitioner. In support of this contention, the respondent sought to introduce into evidence seven letters written by the petitioner and his brother to their mother's attorney.
Read the full summary
Juan R. Brittingham, petitioner Robert's brother, placed $ 241,000 in the petitioner's bank account with instructions that Robert was to use these funds to purchase bonds for his mother. Respondent claimed these funds were gross income to the petitioner. In support of this contention, the respondent sought to introduce into evidence seven letters written by the petitioner and his brother to their mother's attorney. Held, the attorney-client privilege is applicable to communications made to the client's attorney by the client's agent; the privilege may be claimed by the client through her…
1Opinion of the Court
Robert M. Brittingham and Jeanne G. Brittingham, Petitioners v. Commissioner of Internal Revenue, Respondent
Brittingham v. Commissioner
Docket No. 3352-69
United States Tax Court
57 T.C. 91; 1971 U.S. Tax Ct. LEXIS 42;
October 14, 1971, Filed
Decision will be entered for the petitioners.
Juan R. Brittingham, petitioner Robert's brother, placed $ 241,000 in the petitioner's bank account with instructions that Robert was to use these funds to purchase bonds for his mother. Respondent claimed these funds were gross income to the petitioner. In support of this contention, the respondent sought to…
2Cases cited17 opinions
- Commissioner v. WilcoxSupreme Court of the United States · 1946
- Edward E. Colton and Lillian Kaltman v. United States of America, United States of America v. Edward E. ColtonCourt of Appeals for the Second Circuit · 1962
- William O'Dwyer and Sloan O'Dwyer v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1959
- Olender v. United StatesCourt of Appeals for the Ninth Circuit · 1954
- United States v. Walter F. Tellier, Albert Joseph Proctor, Elton B. Jones and Alaska Telephone CorporationCourt of Appeals for the Second Circuit · 1958
12 more not listed; retrieve them via the Exa API.