Taylor v. Commissioner
United States Tax Court
1. Petitioner established commodity trading accounts in the names of three relatives. She advanced all sums required, and, under powers of attorney granted by the nominal owners, she exercised complete control over deposits and withdrawals and over the operation of the accounts. It was her intention to develop the accounts until there was $ 100,000 in each, and, at that time, to turn them over to the nominal owners.
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1. Petitioner established commodity trading accounts in the names of three relatives. She advanced all sums required, and, under powers of attorney granted by the nominal owners, she exercised complete control over deposits and withdrawals and over the operation of the accounts. It was her intention to develop the accounts until there was $ 100,000 in each, and, at that time, to turn them over to the nominal owners. Respondent determined that the income from the accounts was taxable to the petitioner. Held, the nominal owners of the accounts neither contributed nor acquired any part of the…
1Opinion of the Court
Amelia J. Taylor, Petitioner, v. Commissioner of Internal Revenue, Respondent
Taylor v. Commissioner
Docket No. 54131
United States Tax Court
27 T.C. 361; 1956 U.S. Tax Ct. LEXIS 32;
November 27, 1956, Filed
Decision will be entered under Rule 50.
1. Petitioner established commodity trading accounts in the names of three relatives. She advanced all sums required, and, under powers of attorney granted by the nominal owners, she exercised complete control over deposits and withdrawals and over the operation of the accounts. It was her intention to develop the accounts until there was $ 100,000 in…
2Cases cited4 opinions
- Mercil v. CommissionerUnited States Tax Court · 1955
- David Pleason v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1955
- Taylor v. CommissionerUnited States Tax Court · 1956
- Lovering v. United StatesDistrict Court, D. Massachusetts · 1943