Holloway v. Commissioner
United States Tax Court
The decedent, a resident of California, was assisted by his wife in starting a fertilizer business. They started with no capital. She signed notes with him to borrow money and contributed some services, in the earlier stages. They agreed orally that they would share equally. Later a corporation was formed and the stock was issued in the name of the decedent for assets accumulated by decedent and his wife. A gift of most of the stock was soon thereafter made.
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The decedent, a resident of California, was assisted by his wife in starting a fertilizer business. They started with no capital. She signed notes with him to borrow money and contributed some services, in the earlier stages. They agreed orally that they would share equally. Later a corporation was formed and the stock was issued in the name of the decedent for assets accumulated by decedent and his wife. A gift of most of the stock was soon thereafter made. Held, on the facts, the gift was not to the extent of one-half made by the wife, one-half of the stock not being received by her as…
1Opinion of the Court
Estate of H. M. Holloway, Deceased, Harvey S. Holloway, Executor, Petitioner, v. Commissioner of Internal Revenue, Respondent
Holloway v. Commissioner
Docket No. 11427
United States Tax Court
10 T.C. 828; 1948 U.S. Tax Ct. LEXIS 191;
May 13, 1948, Promulgated
Decision will be entered for the respondent.
The decedent, a resident of California, was assisted by his wife in starting a fertilizer business. They started with no capital. She signed notes with him to borrow money and contributed some services, in the earlier stages. They agreed orally that they would share equally. Later a corporation was…
Also in this document: Dissent.
2Cases cited2 opinions
- Neumann v. CommissionerUnited States Tax Court · 1947
- Holloway v. CommissionerUnited States Tax Court · 1948