Legal Opinion

Frank v. Commissioner

United States Board of Tax Appeals

Decided April 11, 1933No. Docket No. 50224PublishedCited by 7 opinions

Held, that income derived from brokerage accounts opened and operated by the petitioner in the names of his three minor daughters was in fact income of said daughters, and is not taxable to the petitioner.

1Opinion of the Court

*1162OPINION.

Trammell:

The sole issue in this case is whether or not the net income reported in the returns of the petitioner’s three daughters for the taxable year 1927 belonged to them or to the petitioner. The amount of gross income reported and deductions claimed are not in dispute. The income in controversy was derived from brokerage accounts opened and operated by the petitioner in the names of his daughters, under the circumstances set out in our findings of fact.

The respondent determined that these trading accounts were in effect trading accounts of the petitioner, and that all profits and…

2Cases cited7 opinions

  1. Richardson v. ShawSupreme Court of the United States · 1908
  2. Tucker v. TuckerSupreme Court of Iowa · 1908
  3. Austin v. HaydenMichigan Supreme Court · 1912
  4. Storey v. StoreyCourt of Appeals for the Seventh Circuit · 1914
  5. Haynes v. GwinSupreme Court of Arkansas · 1919

2 more not listed; retrieve them via the Exa API.

3Cited by7 opinions

  1. Apt v. BirminghamDistrict Court, N.D. Iowa · 1950
  2. Briggs v. CommissionerUnited States Tax Court · 1944
  3. Frank v. CommissionerUnited States Board of Tax Appeals · 1933
  4. Heller v. CommissionerUnited States Board of Tax Appeals · 1940
  5. Jolly's Motor Livery Co. v. CommissionerUnited States Tax Court · 1957

2 more not listed; retrieve them via the Exa API.

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