Haygood v. Commissioner
United States Tax Court
Petitioner deeded properties to each of her two sons and in return took a vendor's lien note from each for the full value of the properties payable $ 3,000 per year, the first payments being due the day after the deeds were executed. Each vendor's lien note was secured by a deed of trust on the properties transferred.
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Petitioner deeded properties to each of her two sons and in return took a vendor's lien note from each for the full value of the properties payable $ 3,000 per year, the first payments being due the day after the deeds were executed. Each vendor's lien note was secured by a deed of trust on the properties transferred. In accordance with her intention when she transferred the properties, petitioner canceled the $ 3,000 payments due the day after the execution of the deeds and in subsequent years canceled the other $ 3,000 payments. Held, petitioner made gifts of the transferred properties to…
1Opinion of the Court
Scott, Judge:
Respondent determined a deficiency in gift tax of petitioner for tlie year 1961 in the amount of $1,882.50.
The issue for decision is whether the gifts made by petitioner in the year 1961 include the entire value of certain property conveyed by petitioner to her sons in the form of a sale of the property for vendor’s lien notes secured by deeds of trust.
FINDINGS OF FACT
Some of the facts have been stipulated and are found accordingly.
Petitioner, an individual residing in Houston, Tex., filed a gift tax return for the calendar year 1961 with the district director of internal revenue…
2Cases cited13 opinions
- Commissioner v. WemyssSupreme Court of the United States · 1945
- Smith v. ShaughnessySupreme Court of the United States · 1943
- Robinette v. HelveringSupreme Court of the United States · 1943
- United States v. H. A. Phillips, Trustee for C. J. Dick Towing Company, BankruptCourt of Appeals for the Fifth Circuit · 1959
- Bergan v. CommissionerUnited States Tax Court · 1943
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3Cited by10 opinions
- Estate of Lydia G. Maxwell, Deceased First National Bank of Long Island Victor C. McCuaig Jr., Executors v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1993
- Estate of Kelley v. CommissionerUnited States Tax Court · 1974
- Laughinghouse v. Comm'rUnited States Tax Court · 1983
- Estate of Musgrove v. United StatesUnited States Court of Federal Claims · 1995
- WilsonUnited States Tax Court · 1992
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