Legal Opinion

Brown v. Commissioner

United States Tax Court

Decided January 31, 1956No. Docket Nos. 52128, 55505Published

In 1947, petitioner William H. Brown redeemed notes in the total amount of $ 32,500, secured by a deed of trust on a parcel of property which he and his wife owned. The notes were not canceled nor was the deed of trust released of record at that time. A trustee held the uncanceled notes as the property of petitioner's two minor children and petitioner filed a gift tax return for 1947 reporting cash gifts of $ 16,250 to each of the children.

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In 1947, petitioner William H. Brown redeemed notes in the total amount of $ 32,500, secured by a deed of trust on a parcel of property which he and his wife owned. The notes were not canceled nor was the deed of trust released of record at that time. A trustee held the uncanceled notes as the property of petitioner's two minor children and petitioner filed a gift tax return for 1947 reporting cash gifts of $ 16,250 to each of the children. In 1949, petitioner canceled the notes and released the deed of trust of record. He then gave each child his personal note for $ 16,250. In 1951 and 1952,…

1Opinion of the Court

William Herbert Brown and Mary F. Brown (Husband and Wife), Petitioners, v. Commissioner of Internal Revenue, Respondent

Brown v. Commissioner

Docket Nos. 52128, 55505

United States Tax Court

25 T.C. 920; 1956 U.S. Tax Ct. LEXIS 275;

January 31, 1956, Filed

Decisions will be entered for the respondent.

In 1947, petitioner William H. Brown redeemed notes in the total amount of $ 32,500, secured by a deed of trust on a parcel of property which he and his wife owned. The notes were not canceled nor was the deed of trust released of record at that time. A trustee held the uncanceled notes as the…

2Cases cited1 opinion

  1. Brown v. CommissionerUnited States Tax Court · 1956

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