Estate of Stranahan v. Commissioner
United States Tax Court
Decedent-taxpayer expected to make a substantial interest payment in 1964 to the Internal Revenue Service and attempted to accelerate his income in that year to avoid losing the tax benefit of the interest deduction by entering into a purported assignment with his son in 1964 which provided, in part, the decedent, in consideration of $115,000 cash, assign all of the dividends to be declared and paid to him with respect to stock of Champion Spark Plug Company, owned by the…
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Decedent-taxpayer expected to make a substantial interest payment in 1964 to the Internal Revenue Service and attempted to accelerate his income in that year to avoid losing the tax benefit of the interest deduction by entering into a purported assignment with his son in 1964 which provided, in part, the decedent, in consideration of $115,000 cash, assign all of the dividends to be declared and paid to him with respect to stock of Champion Spark Plug Company, owned by the assignor, until the assignee had received an aggregate amount of $122,820. Decedent's son issued his check dated December…
1Opinion of the Court
Estate of Frank D. Stranahan, Deceased, The Toledo Trust Company and Duane Stranahan, Co-executors v. Commissioner.
Estate of Stranahan v. Commissioner
Docket No. 1485-69.
United States Tax Court
T.C. Memo 1971-250; 1971 Tax Ct. Memo LEXIS 84; 30 T.C.M. (CCH) 1078; T.C.M. (RIA) 71250;
September 28, 1971, Filed
Decedent-taxpayer expected to make a substantial interest payment in 1964 to the Internal Revenue Service and attempted to accelerate his income in that year to avoid losing the tax benefit of the interest deduction by entering into a purported assignment with his son in 1964 which provided,…
2Cases cited28 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Helvering v. CliffordSupreme Court of the United States · 1940
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Helvering v. HorstSupreme Court of the United States · 1940
23 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Principal Life Insurance Company and Subsidiaries v. United StatesUnited States Court of Federal Claims · 2014