Hitchon v. Commissioner
United States Tax Court
In a family corporation the father owned 1,509 shares of stock, and each of his three sons owned 1 share. The father transferred without consideration 1,508 of his 1,509 shares to the corporation, which were then held as treasury stock.
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In a family corporation the father owned 1,509 shares of stock, and each of his three sons owned 1 share. The father transferred without consideration 1,508 of his 1,509 shares to the corporation, which were then held as treasury stock. Held, that such transfer to the corporation constituted a gift by the father of a portion of his interest to each of his sons, decreasing his own interest to a one-fourth interest and increasing each son's interest to a one-fourth interest; and that under section 1015 of the Internal Revenue Code of 1954, the basis of the interest of each of the sons, for the…
1Opinion of the Court
Estate of Julie B. Hitchon, Deceased, Milton L. Jacobson, Executor, and Herbert M. Hitchon, Petitioners, v. Commissioner of Internal Revenue, Respondent; Estate of Walter G. Hitchon, The Union and New Haven Trust Company, Conservator, and Lucile B. Hitchon, Petitioners, v. Commissioner of Internal Revenue, Respondent
Hitchon v. Commissioner
Docket Nos. 119-64, 132-64
United States Tax Court
45 T.C. 96; 1965 U.S. Tax Ct. LEXIS 24;
October 21, 1965, Filed
Decisions will be entered for the petitioners.
In a family corporation the father owned 1,509 shares of stock, and each of his three sons owned 1…
Also in this document: Concurrence; Dissent.
2Cases cited5 opinions
- Helvering v. HutchingsSupreme Court of the United States · 1941
- Stephen F. Heringer, Mabel H. Heringer, John F. Heringer, and Alta G. Heringer v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1956
- Hitchon v. CommissionerUnited States Tax Court · 1965
- Thompson v. CommissionerUnited States Board of Tax Appeals · 1940
- Diebold v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1952