Legal Opinion

Crane v. Commissioner

United States Tax Court

Decided November 17, 1967No. Docket Nos. 4784-65, 4785-65Published

Held: In determining when and what gifts were made -- 1. When Donald established savings accounts in the name of himself and one of his children, he remained the owner of the funds in the account; 2. When Donald established savings accounts in the name of Dorothy and one of their children, Dorothy and the child each acquired ownership of one-half of the account; 3. When Donald purchased real estate taking title in himself and Dorothy and used the funds in the accounts in the…

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Held: In determining when and what gifts were made -- 1. When Donald established savings accounts in the name of himself and one of his children, he remained the owner of the funds in the account; 2. When Donald established savings accounts in the name of Dorothy and one of their children, Dorothy and the child each acquired ownership of one-half of the account; 3. When Donald purchased real estate taking title in himself and Dorothy and used the funds in the accounts in the name of Dorothy and the children to provide part of the purchase price, the property was not held in a constructive or…

1Opinion of the Court

Dorothy V. Crane, Petitioner v. Commissioner of Internal Revenue, Respondent; Donald V. Crane, Petitioner v. Commissioner of Internal Revenue, Respondent

Crane v. Commissioner

Docket Nos. 4784-65, 4785-65

United States Tax Court

49 T.C. 85; 1967 U.S. Tax Ct. LEXIS 20;

November 17, 1967, Filed

Decisions will be entered under Rule 50.

Held: In determining when and what gifts were made --

1. When Donald established savings accounts in the name of himself and one of his children, he remained the owner of the funds in the account;

2. When Donald established savings accounts in the name of Dorothy and one…

2Cases cited34 opinions

  1. Nebbia v. New YorkSupreme Court of the United States · 1934
  2. Estate of Sanford v. CommissionerSupreme Court of the United States · 1939
  3. Choate v. TrappSupreme Court of the United States · 1912
  4. Burnet v. GuggenheimSupreme Court of the United States · 1933
  5. Healy v. CommissionerSupreme Court of the United States · 1953

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