Anton v. Commissioner
United States Tax Court
Assignment of Income -- Dividend -- Gift of Shares After Declaration but Just Before Record and Payment Date. -- Two fathers, controlling stockholders of a personal holding corporation which declared a dividend on April 17, 1953, to offset an admitted deficiency in personal holding company surtax, gave some of their shares to their children on May 9, the day before the record date and payment date set in the declaration of the dividend.
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Assignment of Income -- Dividend -- Gift of Shares After Declaration but Just Before Record and Payment Date. -- Two fathers, controlling stockholders of a personal holding corporation which declared a dividend on April 17, 1953, to offset an admitted deficiency in personal holding company surtax, gave some of their shares to their children on May 9, the day before the record date and payment date set in the declaration of the dividend. Held, the Commissioner did not err in taxing the dividends on those shares to the fathers. Helvering v. Horst, 311 U.S. 112.
1Opinion of the Court
Mark G. Anton and Adele B. Anton, et al., 1 Petitioners, v. Commissioner of Internal Revenue, Respondent
Anton v. Commissioner
Docket Nos. 74337, 74336
United States Tax Court
34 T.C. 842; 1960 U.S. Tax Ct. LEXIS 92;
August 15, 1960, Filed
Decisions will be entered for the respondent.
Assignment of Income -- Dividend -- Gift of Shares After Declaration but Just Before Record and Payment Date. -- Two fathers, controlling stockholders of a personal holding corporation which declared a dividend on April 17, 1953, to offset an admitted deficiency in personal holding company surtax, gave some of their…
2Cases cited14 opinions
- Lucas v. EarlSupreme Court of the United States · 1930
- Helvering v. HorstSupreme Court of the United States · 1940
- Martindell v. Fiduciary Counsel, Inc.Supreme Court of New Jersey · 1943
- Crellin's Estate v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1953
- Holmes v. CommissionerUnited States Tax Court · 1943
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