Dickson v. Commissioner
United States Tax Court
The $41,250 voted for petitioner by Berlin & Jones on October 30, 1956, was not a voluntary act proceeding from detached and disinterested generosity, and hence was not a gift within the meaning of section 102 of the Internal Revenue Code of 1954.
1Opinion of the Court
Katharine Shaw Dickson v. Commissioner.
Dickson v. Commissioner
Docket No. 90755.
United States Tax Court
T.C. Memo 1964-191; 1964 Tax Ct. Memo LEXIS 146; 23 T.C.M. (CCH) 1161; T.C.M. (RIA) 64191;
July 14, 1964
The $41,250 voted for petitioner by Berlin & Jones on October 30, 1956, was not a voluntary act proceeding from detached and disinterested generosity, and hence was not a gift within the meaning of section 102 of the Internal Revenue Code of 1954.
Seth H. Dubin, 521 5th Ave., New York, N. Y. for the petitioner. James Q. Smith, for the respondent.
ARUNDELL
Memorandum Findings of Fact and Opinion
A…
2Cases cited10 opinions
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Willkie v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1942
- Eva L. Gaugler, on Behalf of Herself and as Under the Last Will and Testament of Raymond C. Gaugler, Deceased v. United StatesCourt of Appeals for the Second Circuit · 1963
- Mildred W. Smith v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1962
- Martin v. CommissionerUnited States Tax Court · 1961
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