Rosenwald v. Commissioner
United States Board of Tax Appeals
An organization known as Julius Rosenwald Fund was organized in 1917 for charitable, scientific, educational, and religious purposes. During the years in controversy the petitioner gave, through the medium of purported assignments, dividends on stocks, interest on a promissory note and rent from certain properties owned by the petitioner. He also clipped and gave to that fund, prior to maturity, coupons from the United States Liberty bonds.
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An organization known as Julius Rosenwald Fund was organized in 1917 for charitable, scientific, educational, and religious purposes. During the years in controversy the petitioner gave, through the medium of purported assignments, dividends on stocks, interest on a promissory note and rent from certain properties owned by the petitioner. He also clipped and gave to that fund, prior to maturity, coupons from the United States Liberty bonds. Petitioner, at all times during the period of these purported assignments, retained ownership and possession of the stocks, bonds, notes and real estate…
1Opinion of the Court
*359OPINION.
Morris:
While the sole question presented for consideration by the first allegation of error relates to the inclusion in the petitioner’s income of dividends, interest, rents and miscellaneous income alleged to have been assigned by him to The Julius Rosenwald Fund, and, while the same problems arise with respect to all of those items, we deem it advisable to dispose of the dividend item separately, since that question has been heretofore considered and passed upon by the Board.
In Fred W. Warner, 5 B. T. A. 963, one of the questions was whether certain income disposed of by the…
2Cases cited8 opinions
- Irwin v. GavitSupreme Court of the United States · 1925
- Rensselaer & S. R. v. IrwinCourt of Appeals for the Second Circuit · 1918
- Houston Belt & Terminal Ry. Co. v. United StatesCourt of Appeals for the Fifth Circuit · 1918
- Blalock v. Georgia Ry. & Electric Co.Court of Appeals for the Fifth Circuit · 1917
- Anderson v. Morris & E. R.Court of Appeals for the Second Circuit · 1914
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3Cited by8 opinions
- McInerney v. CommissionerUnited States Board of Tax Appeals · 1933
- Drake v. CommissionerUnited States Board of Tax Appeals · 1934
- Browning v. CommissionerUnited States Board of Tax Appeals · 1929
- Field v. CommissionerUnited States Board of Tax Appeals · 1929
- Horst v. CommissionerUnited States Board of Tax Appeals · 1939
3 more not listed; retrieve them via the Exa API.