Taylor v. Commissioner
United States Tax Court
1. Petitioner established commodity trading accounts in the names of three relatives. She advanced all sums required, and, under powers of attorney granted by the nominal owners, she exercised complete control over deposits and withdrawals and over the operation of the accounts. It was her intention to develop the accounts until there was $ 100,000 in each, and, at that time, to turn them over to the nominal owners.
Read the full summary
1. Petitioner established commodity trading accounts in the names of three relatives. She advanced all sums required, and, under powers of attorney granted by the nominal owners, she exercised complete control over deposits and withdrawals and over the operation of the accounts. It was her intention to develop the accounts until there was $ 100,000 in each, and, at that time, to turn them over to the nominal owners. Respondent determined that the income from the accounts was taxable to the petitioner. Held, the nominal owners of the accounts neither contributed nor acquired any part of the…
1Opinion of the Court
OPINION.
Rice, Judge:
The principal issue to be decided herein is whether petitioner is taxable upon the income of various commodity trading accounts which she maintained in the names of three relatives during the years 1946 and 1947.
Petitioner contends that each of these accounts was owned by the person in whose name it had been established, that she simply acted as their agent, and that she is not taxable on the income therefrom since her only function was that of manager of the accounts. She argues that the various cash advances which she made in order to establish the accounts, and later,…
2Cases cited3 opinions
- Mercil v. CommissionerUnited States Tax Court · 1955
- David Pleason v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1955
- Lovering v. United StatesDistrict Court, D. Massachusetts · 1943
3Cited by22 opinions
- Lone Manor Farms, Inc. v. CommissionerUnited States Tax Court · 1974
- Schwartz v. CommissionerUnited States Tax Court · 1963
- Estate of Applestein v. CommissionerUnited States Tax Court · 1983
- Olaf E. Taxeraas, Administrator of the Estate of Carl Taxeraas and Irene Taxeraas v. United StatesCourt of Appeals for the Eighth Circuit · 1959
- Asa Investerings P'Ship v. Comm'rUnited States Tax Court · 2002
17 more not listed; retrieve them via the Exa API.