Estate of Cooper v. Commissioner
United States Tax Court
1. On or about December 1944, William P. Cooper purchased prepaid installment share accounts of the Perpetual Building and Loan Association in the amount of $2,273.26, which he held until his demise on December 28, 1948. During the years said share accounts were in existence (held almost exclusively by members of the Cooper family), Perpetual credited dividends thereto at various times in amounts ranging from 200 to 600 per cent representing a portion of its earnings.
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1. On or about December 1944, William P. Cooper purchased prepaid installment share accounts of the Perpetual Building and Loan Association in the amount of $2,273.26, which he held until his demise on December 28, 1948. During the years said share accounts were in existence (held almost exclusively by members of the Cooper family), Perpetual credited dividends thereto at various times in amounts ranging from 200 to 600 per cent representing a portion of its earnings. The current dividend on other types of share accounts issued by Perpetual during the same period was four per cent. Under…
1Opinion of the Court
Estate of William P. Cooper, Deceased, Daisy H. Cooper, Executrix v. Commissioner.
Estate of Cooper v. Commissioner
Docket No. 64788.
United States Tax Court
T.C. Memo 1960-98; 1960 Tax Ct. Memo LEXIS 192; 19 T.C.M. (CCH) 521; T.C.M. (RIA) 60098;
May 18, 1960
1. On or about December 1944, William P. Cooper purchased prepaid installment share accounts of the Perpetual Building and Loan Association in the amount of $2,273.26, which he held until his demise on December 28, 1948. During the years said share accounts were in existence (held almost exclusively by members of the Cooper family), Perpetual…
2Cases cited20 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Higgins v. SmithSupreme Court of the United States · 1940
- Eli D. Goodstein v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. Eli D. GoodsteinCourt of Appeals for the First Circuit · 1959
- Goodstein v. CommissionerUnited States Tax Court · 1958
- H. O. Williams and Mrs. Ada L. Williams v. United StatesCourt of Appeals for the Fifth Circuit · 1955
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