Legal Opinion

Cooley v. Commissioner

United States Board of Tax Appeals

Decided March 24, 1933No. Docket No. 63282Published

1. TENANTS BY THE ENTIRETY - INCOME THEREFROM IN MASSACHUSETTS TAXABLE TO THE HUSBAND. - Petitioner and his wife were domiciled in the State of Massachusetts and owned certain stocks and bonds as tenants by the entirety.

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1. TENANTS BY THE ENTIRETY - INCOME THEREFROM IN MASSACHUSETTS TAXABLE TO THE HUSBAND. - Petitioner and his wife were domiciled in the State of Massachusetts and owned certain stocks and bonds as tenants by the entirety. Held, that under the laws of the State of Massachusetts the husband has the absolute and exclusive right to the control, use, possession, rents, issues and profits of property held as tenants by the entirety and therefore dividends and interest received from such property during the taxable year in question were all taxable to the husband. 2. SUBSCRIPTION RIGHTS TO PURCHASE…

1Opinion of the Court

ROBERT C. COOLEY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Cooley v. Commissioner

Docket No. 63282.

United States Board of Tax Appeals

27 B.T.A. 986; 1933 BTA LEXIS 1262;

March 24, 1933, Promulgated

1. TENANTS BY THE ENTIRETY - INCOME THEREFROM IN MASSACHUSETTS TAXABLE TO THE HUSBAND. - Petitioner and his wife were domiciled in the State of Massachusetts and owned certain stocks and bonds as tenants by the entirety. Held, that under the laws of the State of Massachusetts the husband has the absolute and exclusive right to the control, use, possession, rents, issues and profits…

2Cases cited2 opinions

  1. Powel v. CommissionerUnited States Board of Tax Appeals · 1932
  2. Cooley v. CommissionerUnited States Board of Tax Appeals · 1933

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