Ward v. Commissioner
United States Tax Court
In 1940, H entered into a land contract to purchase ranch land in Florida. Over the next 4 years, H and his wife, W, each contributed indeterminate amounts of money to pay the installments of the purchase price of the ranch land and to acquire an adjacent parcel of ranch land. H took title to both parcels in his name alone. In 1978, H and W deeded the ranch land to a newly formed corporation, J, except for three small plots deeded as gifts to their sons and their wives.
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In 1940, H entered into a land contract to purchase ranch land in Florida. Over the next 4 years, H and his wife, W, each contributed indeterminate amounts of money to pay the installments of the purchase price of the ranch land and to acquire an adjacent parcel of ranch land. H took title to both parcels in his name alone. In 1978, H and W deeded the ranch land to a newly formed corporation, J, except for three small plots deeded as gifts to their sons and their wives. In return for the ranch, H and W each received 43.7 percent of the stock in J. The three sons of H and W contributed cattle…
1Opinion of the Court
SIMPSON, Judge:
The Commissioner determined deficiencies in the petitioners’ Federal gift taxes as follows:
Petitioner 12/31/78 12/31/79 12/31/80 3/31/81
Charles W. Ward $201,802.14 $99,276.29 $11,997 $14,920.34
Virginia P. Ward --- 39,090.00 9,882 11,271.70
The issues for decision are: (1) Whether Charles W. Ward made a gift to his wife, Virginia P. Ward, of 437 shares of stock in J-Seven Ranch, Inc. (J-Seven), in 1978, and if so, the value of such shares; (2) the number of acres of land given to the petitioners’ sons and their wives in 1978; (3) the fair market values of gifts of stock in…
2Cases cited90 opinions
- Canakaris v. CanakarisSupreme Court of Florida · 1980
- Commissioner v. Estate of BoschSupreme Court of the United States · 1967
- Morgan v. CommissionerSupreme Court of the United States · 1940
- United States v. National Bank of CommerceSupreme Court of the United States · 1985
- Estate of Sanford v. CommissionerSupreme Court of the United States · 1939
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3Cited by66 opinions
- Estate of Newhouse v. CommissionerUnited States Tax Court · 1990
- ESTATE OF DAVIS v. COMMISSIONERUnited States Tax Court · 1998
- Estate of Spruill v. CommissionerUnited States Tax Court · 1987
- Irene Eisenberg v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1998
- Shepherd v. CommissionerUnited States Tax Court · 2000
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