Richardson v. Commissioner
United States Board of Tax Appeals
1. Taxpayer owned certain stock, the certificates for which were deposited in his safe deposit box in North Carolina. On May 18, 1932, he informed his wife he had given this stock to her, but made no effort to have it transferred into her name or to give her access to the safe deposit box.
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1. Taxpayer owned certain stock, the certificates for which were deposited in his safe deposit box in North Carolina. On May 18, 1932, he informed his wife he had given this stock to her, but made no effort to have it transferred into her name or to give her access to the safe deposit box. On May 27, 1932, while in New York, he had his agent prepare two assignments which were signed and delivered to the latter in New York with instructions to hold them until the taxpayer returned to North Carolina and forwarded the certificates, whereupon the agent was to have new certificates issued in the…
1Opinion of the Court
*928OPINION.
Mellott :
Respondent determined deficiencies in petitioner’s gift tax in the amounts of $10,991.69 for the year 1932 and $13,298.25 for the year 1934. The deficiency for 1932 results from respondent’s determination that petitioner made a gift of 55,699 shares of Vick Financial Corporation stock subsequent to June 6, 1932 (the effective date of the gift tax provisions, section 501 et seq., Revenue Act of 1932). This deficiency will be considered first.
The facts relating to the 1932 transactions, which petitioner contends show gifts consummated prior to June 6 of that year and respondent…
2Cases cited5 opinions
- Burnet v. GuggenheimSupreme Court of the United States · 1933
- In Re the Accounting of Van AlstyneNew York Court of Appeals · 1913
- Vincent v. RixNew York Court of Appeals · 1928
- Allen-West Commission Co. v. GrumblesCourt of Appeals for the Eighth Circuit · 1904
- Bickford v. MattocksSupreme Judicial Court of Maine · 1901
3Cited by16 opinions
- CTUW Hollingsworth v. CommissionerUnited States Tax Court · 1986
- Apt v. BirminghamDistrict Court, N.D. Iowa · 1950
- Londen v. CommissionerUnited States Tax Court · 1965
- Dougherty v. CommissionerUnited States Tax Court · 1974
- Estate of DuBois v. CommissionerUnited States Tax Court · 1994
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