Legal Opinion

Jones v. Commissioner

United States Tax Court

Decided February 8, 1963No. Docket Nos. 85869, 91351PublishedCited by 6 opinions

Spouse's failure to signify her consent by signing the consent-of-spouse statement on the face of petitioner's gift tax returns, or otherwise, precludes petitioner from having one-half of his gifts considered as having been made by his spouse for gift tax purposes.

1Opinion of the Court

OPINION.

Dkennen, Judge:

Respondent has determined in these consolidated proceedings that there are due from petitioner deficiencies in gift tax for the years 1956 and 1957 in the respective amounts of $6,517.13 and $3,600.

The only issue for decision is whether petitioner’s wife, Annabel L. Jones (hereinafter called Annabel), signified her consent, within the meaning of section 2513(a) (2),1 to have the gifts made by petitioner during 1956 and 1957 considered as made one-half by her.

The case was submitted under Rule 30 of the Rules of Practice of this Court. The stipulated facts are found…

2Cases cited10 opinions

  1. Howell v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1949
  2. Howell v. CommissionerUnited States Tax Court · 1948
  3. Kann v. Commissioner of Internal Revenue. Kann's Estate v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1954
  4. Muriel Heim v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1958
  5. Bayley v. CommissionerUnited States Tax Court · 1960

5 more not listed; retrieve them via the Exa API.

3Cited by6 opinions

  1. Clark v. CommissionerUnited States Tax Court · 1975
  2. Bruce v. Comm'rUnited States Tax Court · 2014
  3. Clark v. CommissionerUnited States Tax Court · 1975
  4. Jason Alan Bruce v. CommissionerUnited States Tax Court · 2014
  5. Jason Alan Bruce v. CommissionerUnited States Tax Court · 2014

1 more not listed; retrieve them via the Exa API.

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