Commissioner of Corporations & Taxation v. Williston

The taxpayer, a resident of this Commonwealth and the owner of certain corporate bonds, detached the interest coupons and made a gift of them about Christmas time in 1934 to his daughter, a married woman living with her husband in the State of New York. These coupons were payable to bearer and matured in 1935. In December, 1935, he made a similar gift to her of coupons payable in 1936. The transfer of these coupons was disclosed by the taxpayer in the returns filed by him in 1936 and 1937. The commissioner of corporations and taxation assessed a tax for each of these two years upon the amount…