Jacobs v. Commissioner
United States Board of Tax Appeals
1. An elder brother agreed to purchase a hotel property at a price asserted to be less than its true value. With the intention of conferring a benefit, he caused the property to be conveyed to a younger brother, who agreed to assume and pay the purchase price and an additional amount. Upon a sale by the younger brother, he claims a gift was made and that profit should be computed by using as a base the value of the property when acquired.
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1. An elder brother agreed to purchase a hotel property at a price asserted to be less than its true value. With the intention of conferring a benefit, he caused the property to be conveyed to a younger brother, who agreed to assume and pay the purchase price and an additional amount. Upon a sale by the younger brother, he claims a gift was made and that profit should be computed by using as a base the value of the property when acquired. Denied, upon the grounds (1) that the transaction lacked one of the elements of a gift, i.e., absence of a valuable consideration; and (2) that the evidence…
1Opinion of the Court
E. LOUIS JACOBS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Jacobs v. Commissioner
Docket No. 26249.
United States Board of Tax Appeals
20 B.T.A. 529; 1930 BTA LEXIS 2097;
August 11, 1930, Promulgated
1. An elder brother agreed to purchase a hotel property at a price asserted to be less than its true value. With the intention of conferring a benefit, he caused the property to be conveyed to a younger brother, who agreed to assume and pay the purchase price and an additional amount. Upon a sale by the younger brother, he claims a gift was made and that profit should be computed by…
2Cases cited1 opinion
- Jacobs v. CommissionerUnited States Board of Tax Appeals · 1930