Mitchell v. Commissioner
United States Board of Tax Appeals
A husband, having an account with brokers in his name, arranged for an account to be opened in the name of his wife. Thereafter he ordered the brokers to make purchases and sales for the account of his wife. The only stocks purchased for the wife's account were those ordered sold by the husband on the same day and the stocks sold for the account of the wife were purchased on the same day for the account of the husband.
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A husband, having an account with brokers in his name, arranged for an account to be opened in the name of his wife. Thereafter he ordered the brokers to make purchases and sales for the account of his wife. The only stocks purchased for the wife's account were those ordered sold by the husband on the same day and the stocks sold for the account of the wife were purchased on the same day for the account of the husband. He furnished the funds to pay for the securities acquired for the wife's account. The stocks in the name of the wife were kept in the husband's safety deposit box with stocks…
1Opinion of the Court
ESTATE OF ELIOT W. MITCHELL, DECEASED, MANUFACTURERS & TRADERS TRUST COMPANY AND ALICE FRANK MITCHELL, EXECUTORS, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Mitchell v. Commissioner
Docket No. 76401.
United States Board of Tax Appeals
37 B.T.A. 161; 1938 BTA LEXIS 1082;
January 21, 1938, Promulgated
A husband, having an account with brokers in his name, arranged for an account to be opened in the name of his wife. Thereafter he ordered the brokers to make purchases and sales for the account of his wife. The only stocks purchased for the wife's account were those ordered sold by…
2Cases cited1 opinion
- Mitchell v. CommissionerUnited States Board of Tax Appeals · 1938