Bassett v. Commissioner
United States Board of Tax Appeals
1. The petitioner in contemplation of the sale of certain stock made an irrevocable gift on trust of part of his shares to his wife for life, with reversion to himself on her death, naming himself as trustee. The executory contract of sale was later carried out and petitioner received the proceeds of the sale as trustee.
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1. The petitioner in contemplation of the sale of certain stock made an irrevocable gift on trust of part of his shares to his wife for life, with reversion to himself on her death, naming himself as trustee. The executory contract of sale was later carried out and petitioner received the proceeds of the sale as trustee. Held, that a bona fide trust of the shares was created and the capital gain on the sale was not income taxable to the petitioner under section 166 or 167 of the Revenue Act of 1928. 2. Under the same sale in 1929, $20,000 of the purchase price was deposited by the buyer in a…
1Opinion of the Court
PRESTON R. BASSETT, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Bassett v. Commissioner
Docket No. 63263.
United States Board of Tax Appeals
33 B.T.A. 182; 1935 BTA LEXIS 790;
October 11, 1935, Promulgated
1. The petitioner in contemplation of the sale of certain stock made an irrevocable gift on trust of part of his shares to his wife for life, with reversion to himself on her death, naming himself as trustee. The executory contract of sale was later carried out and petitioner received the proceeds of the sale as trustee. Held, that a bona fide trust of the shares was created and…
2Cases cited18 opinions
- North American Oil Consolidated v. BurnetSupreme Court of the United States · 1932
- Lucas v. American Code Co.Supreme Court of the United States · 1930
- Crooks v. HarrelsonSupreme Court of the United States · 1930
- Reinecke v. Northern Trust Co.Supreme Court of the United States · 1929
- Burnet v. WellsSupreme Court of the United States · 1933
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