Johnson v. Commissioner
United States Tax Court
1. Petitioners Joseph Johnson, David Johnson, and Clay Johnson borrowed $ 200,000, $ 200,000, and $ 175,000, respectively, from a bank, signing 30-day notes therefor. The words "without personal liability" were written after their signatures.
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1. Petitioners Joseph Johnson, David Johnson, and Clay Johnson borrowed $ 200,000, $ 200,000, and $ 175,000, respectively, from a bank, signing 30-day notes therefor. The words "without personal liability" were written after their signatures. At the same time each petitioner transferred to the bank as collateral security for his loan 50,000 shares of stock having a basis of $ 10,812.50 and a fair market value exceeding $ 500,000. Immediately thereafter each of these petitioners established an irrevocable trust for his children, transferring thereto, as the corpus, his ownership in the stock…
1Opinion of the Court
Bruce, Judge:
Respondent determined deficiencies in the income taxes of the petitioners for the taxable years and in amounts as follows:
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Certain adjustments contained in the statutory notices of deficiency have been conceded by the respective petitioners.
The principal issue, common to each of the cases, is whether the respective petitioners realized taxable income in 1965 upon the transfer of 50,000 shares of stock, having a basis of $10,812.50 and a fair market value of $500,000, to a trust for the benefit of their children, where such stock had been pledged as collateral…
2Cases cited22 opinions
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Crane v. CommissionerSupreme Court of the United States · 1947
- Weiss v. StearnSupreme Court of the United States · 1924
- Corliss Lamont and Margaret I. Lamont v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1964
- Hazard v. CommissionerUnited States Tax Court · 1946
17 more not listed; retrieve them via the Exa API.
3Cited by78 opinions
- Golanty v. CommissionerUnited States Tax Court · 1979
- Allen v. CommissionerUnited States Tax Court · 1979
- Hager v. CommissionerUnited States Tax Court · 1981
- Diedrich v. CommissionerSupreme Court of the United States · 1982
- Drobny v. CommissionerUnited States Tax Court · 1986
73 more not listed; retrieve them via the Exa API.