Legal Opinion

Ginsberg v. Commissioner

United States Tax Court

Decided March 31, 1961No. Docket Nos. 72468, 72469Published

Transferee Liability. -- The father of the petitioners, at a time when he was insolvent and liable for Federal income taxes, with intent to make valid gifts caused a corporation of which he was the sole stockholder to cancel his certificate of stock and reissue certificates in the names of his sons, the petitioners. One of the petitioners, Robert, signed the certificates as secretary of the corporation, and the stock was thereafter held by the attorney for the corporation.

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Transferee Liability. -- The father of the petitioners, at a time when he was insolvent and liable for Federal income taxes, with intent to make valid gifts caused a corporation of which he was the sole stockholder to cancel his certificate of stock and reissue certificates in the names of his sons, the petitioners. One of the petitioners, Robert, signed the certificates as secretary of the corporation, and the stock was thereafter held by the attorney for the corporation. The other petitioner, Donald, had not reached majority, was away from home at the times the certificates were issued, and…

1Opinion of the Court

Robert Ginsberg, Petitioner, v. Commissioner of Internal Revenue, Respondent. Donald Ginsberg, Petitioner, v. Commissioner of Internal Revenue, Respondent

Ginsberg v. Commissioner

Docket Nos. 72468, 72469

United States Tax Court

35 T.C. 1148; 1961 U.S. Tax Ct. LEXIS 184;

March 31, 1961, Filed

Decisions will be entered under Rule 50.

Transferee Liability. -- The father of the petitioners, at a time when he was insolvent and liable for Federal income taxes, with intent to make valid gifts caused a corporation of which he was the sole stockholder to cancel his certificate of stock and reissue…

2Cases cited15 opinions

  1. Commissioner v. SternSupreme Court of the United States · 1958
  2. Beaver v. . BeaverNew York Court of Appeals · 1889
  3. Gobins v. Comm'rUnited States Tax Court · 1952
  4. Ginsberg v. CommissionerUnited States Tax Court · 1961
  5. In re the Estate of BabcockNew York Surrogate's Court · 1914

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