Ferguson v. Commissioner
United States Board of Tax Appeals
1. Petitioner transferred, by an assignment, 430 units of beneficial interest in a trust, the corpus of which consisted solely of installment obligations.
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1. Petitioner transferred, by an assignment, 430 units of beneficial interest in a trust, the corpus of which consisted solely of installment obligations. Held, that the transfer of units of beneficial interest was not the equivalent of the disposition of installment obligations within the meaning of section 44(d) of the Revenue Act of 1928. 2. Salaries, fees, commissions and other compensation received by petitioner subsequent to a certain separation agreement are his separate income and not community income, following Muriel Oakes Ames,30 B.T.A. 516.
1Opinion of the Court
HAROLD G. FERGUSON, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Ferguson v. Commissioner
Docket No. 70463.
United States Board of Tax Appeals
34 B.T.A. 522; 1936 BTA LEXIS 693;
April 30, 1936, Promulgated
1. Petitioner transferred, by an assignment, 430 units of beneficial interest in a trust, the corpus of which consisted solely of installment obligations. Held, that the transfer of units of beneficial interest was not the equivalent of the disposition of installment obligations within the meaning of section 44(d) of the Revenue Act of 1928.
2. Salaries, fees, commissions and other…
2Cases cited9 opinions
- Brown v. FletcherSupreme Court of the United States · 1915
- Ross v. CommissionerUnited States Board of Tax Appeals · 1933
- Jones v. CommissionerUnited States Board of Tax Appeals · 1934
- Meagher v. CommissionerUnited States Board of Tax Appeals · 1930
- Huntington v. CommissionerUnited States Board of Tax Appeals · 1929
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