Legal Opinion
Publicker v. Commissioner of Internal Revenue
Court of Appeals for the Third Circuit
Decided August 19, 1953No. 10951PublishedCited by 31 opinions
1Opinion of the Court
BIGGS, Chief Judge.
The issue before us is the value for gift tax purposes of jewelry given by the petitioner, Mrs. Rose Publicker, to her daughter in 1946 and 1947.
26 U.S.C.A. § 1000(a) states: “For the calendar year 1940 and each calendar year thereafter a tax, computed as provided in section 1001, shall be imposed upon the transfer during such calendar year by any individual, resident or nonresident, of property by gift. * * * ” Section 1005 provides : “If the gift is made in property, the value thereof at the date of the gift shall be considered the amount of the gift.” Treasury…
2Cases cited8 opinions
- Commissioner v. FlowersSupreme Court of the United States · 1946
- Helvering v. R. J. Reynolds Tobacco Co.Supreme Court of the United States · 1939
- Guggenheim v. RasquinSupreme Court of the United States · 1941
- United States v. Dakota-Montana Oil Co.Supreme Court of the United States · 1933
- Powers v. CommissionerSupreme Court of the United States · 1941
3 more not listed; retrieve them via the Exa API.
3Cited by31 opinions
- Estate of Smith v. CommissionerUnited States Tax Court · 1972
- Dellinger v. CommissionerUnited States Tax Court · 1959
- Holt Cargo Systems, Inc. v. Delaware River Port AuthorityDistrict Court, E.D. Pennsylvania · 1998
- Jarre v. CommissionerUnited States Tax Court · 1975
- Amerada Hess Corp. v. CommissionerCourt of Appeals for the Third Circuit · 1975
26 more not listed; retrieve them via the Exa API.