Edson v. Commissioner
United States Board of Tax Appeals
1. Petitioner held taxable upon gain from the sale in 1919 of certain shares of stock alleged to have been previously conveyed as a gift to her daughter. 2. Where personal property was transferred subject to conditions limiting its use by the transferee, with a possibility of reversion to the transferor, and where the facts show that the transferor did not intend to relinquish all dominion and control of the property, held, that such transfer did not constitute an absolute…
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1. Petitioner held taxable upon gain from the sale in 1919 of certain shares of stock alleged to have been previously conveyed as a gift to her daughter. 2. Where personal property was transferred subject to conditions limiting its use by the transferee, with a possibility of reversion to the transferor, and where the facts show that the transferor did not intend to relinquish all dominion and control of the property, held, that such transfer did not constitute an absolute gift inter vivos. 3. The exchange of stock of one corporation for debenture bonds of another corporation held to have…
1Opinion of the Court
MARGARET M. EDSON, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Edson v. Commissioner
Docket No. 11919.
United States Board of Tax Appeals
11 B.T.A. 621; 1928 BTA LEXIS 3752;
April 17, 1928, Promulgated
1. Petitioner held taxable upon gain from the sale in 1919 of certain shares of stock alleged to have been previously conveyed as a gift to her daughter.
2. Where personal property was transferred subject to conditions limiting its use by the transferee, with a possibility of reversion to the transferor, and where the facts show that the transferor did not intend to relinquish all…
2Cases cited1 opinion
- Edson v. CommissionerUnited States Board of Tax Appeals · 1928