Atkins v. Commissioner
United States Board of Tax Appeals
On May 3, 1923, the decedent, then living in Shreveport, Louisiana, drew a draft upon his broker in Philadelphia in the amount of $32,500 and deposited same for collection, to which were attached certificates for 26,000 shares of stock of the Shreveport Producing & Refining Corporation; on May 15, 1923, he deposited a like draft drawn upon the broker for $29,177.50, to which were attached certificates for 23,342 shares of stock of the same corporation; on May 12, 1923, and…
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On May 3, 1923, the decedent, then living in Shreveport, Louisiana, drew a draft upon his broker in Philadelphia in the amount of $32,500 and deposited same for collection, to which were attached certificates for 26,000 shares of stock of the Shreveport Producing & Refining Corporation; on May 15, 1923, he deposited a like draft drawn upon the broker for $29,177.50, to which were attached certificates for 23,342 shares of stock of the same corporation; on May 12, 1923, and again on May 21, 1923, the decedent loaned to an associate money for the repurchase of these shares from the broker at an…
1Opinion of the Court
*501OPINION.
Smith:
These proceedings, consolidated for hearing, are for re-determination of the following deficiencies in income tax:
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J. B. Atkins died on October 28,1928. J. B. Atkins and Mrs. J. B. Atkins were members of a marital community, resident in Shreveport, Louisiana, from January 1 to October 28, 1923. Separate income tax returns were filed for each- — that for Mrs. J. B. Atkins covering the calendar year, and that for the decedent to the date of his death. In each return was reported one half of the income of the marital community and in the audit of the returns the…
2Cases cited4 opinions
- Wyoming v. ColoradoSupreme Court of the United States · 1932
- Succession of McGuireSupreme Court of Louisiana · 1922
- Oliver v. United StatesSupreme Court of the United States · 1925
- Atkins v. CommissionerUnited States Board of Tax Appeals · 1927
3Cited by2 opinions
- Atkins v. CommissionerUnited States Board of Tax Appeals · 1933
- Estate of Estroff v. CommissionerUnited States Tax Court · 1983