Housman v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
1Opinion of the Court
PATTERSON, Circuit Judge.
The Commissioner of Internal Revenue ruled that $66,093.54 paid by the petitioner to her son William in 1933 was subject to gift tax under the Revenue Act of 1932 and gave notice of tax deficiency of $2,490.80. The petitioner took the matter to the Board of Tax Appeals, claiming that the payment was not a gift but was made as the result of a trust impressed on her income and also as the result of an enforceable agreement between her and her son. The Board held that the payment was subject to gift tax. The petitioner has brought the case here for review. She is content…
2Cases cited10 opinions
- Lyeth v. HoeySupreme Court of the United States · 1938
- Trustees of Amherst College v. RitchNew York Court of Appeals · 1897
- Matter of Will of O'HaraNew York Court of Appeals · 1884
- Neagle v. McMullenIllinois Supreme Court · 1929
- Orth v. OrthIndiana Supreme Court · 1895
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3Cited by10 opinions
- Delaney v. GardnerCourt of Appeals for the First Circuit · 1953
- Old Colony Trust Co. v. Commissioner of Corporations & TaxationMassachusetts Supreme Judicial Court · 1964
- Lucille Howard v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1971
- Helvering v. Safe Deposit & Trust Co.Court of Appeals for the Fourth Circuit · 1941
- Alexander v. United StatesUnited States Court of Claims · 1981
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