Guaranty Trust Co. v. Commissioner
United States Board of Tax Appeals
Checks given by a husband to his wife under circumstances showing that the husband did not give up complete control over the money, held not valid gifts to the wife.
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Checks given by a husband to his wife under circumstances showing that the husband did not give up complete control over the money, held not valid gifts to the wife. Consequently loans to the husband of the same money by the wife as trustee under trusts created at husband's suggestion held not to be obligations contracted bona fide and for full consideration in money or money's worth so as to be deductible from his gross estate under section 303(a)(1) of the Revenue Act of 1926.
1Opinion of the Court
GUARANTY TRUST COMPANY OF NEW YORK AND J. WHITNEY PETERSON, EXECUTORS OF WILL OF JONATHAN PETERSON, DECEASED, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Guaranty Trust Co. v. Commissioner
Docket No. 72503.
United States Board of Tax Appeals
35 B.T.A. 916; 1937 BTA LEXIS 814;
April 23, 1937, Promulgated
Checks given by a husband to his wife under circumstances showing that the husband did not give up complete control over the money, held not valid gifts to the wife. Consequently loans to the husband of the same money by the wife as trustee under trusts created at husband's…
2Cases cited22 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Beaver v. . BeaverNew York Court of Appeals · 1889
- In Re the Accounting of Van AlstyneNew York Court of Appeals · 1913
- In Re the Judicial Settlement of the Accounts of BolinNew York Court of Appeals · 1892
- Gannon v. . McGuireNew York Court of Appeals · 1899
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