Hearn v. Commissioner
United States Board of Tax Appeals
Held, that the alleged parol assignment by this taxpayer, now deceased, of income to arise in the future has not been proved, and does not relieve her estate from the liability for the tax thereon when the income was received.
1Opinion of the Court
*1104OPINION.
Love:
Upon the facts, we must decide the issue in favor of the respondent.
It is admitted that for reasons that seemed expedient to those concerned, there was no transfer or assignment of the land itself or the oil and gas leases that were executed thereon. The title to these was in Mrs. R. A. Hearn and, for anything that appears in the record, so remained to the day of her death. The contention advanced is that at the family meeting of August 20, 1922, Mrs. Hearn then and there made a parol assignment of one-half of the rents and revenues that might be derived from this property.
We are…
2Cited by3 opinions
- Bibby v. CommissionerUnited States Tax Court · 1965
- Bibby v. CommissionerUnited States Tax Court · 1965
- Hearn v. CommissionerUnited States Board of Tax Appeals · 1929