Godwin v. Commissioner
United States Board of Tax Appeals
1. An alleged gift by petitioner to his wife held not proven. 2. A redemption of preferred shares by a corporation with cash held to be the distribution of a taxable dividend, Revenue Act of 1926, sec. 201(g). 3. The inclusion in taxpayer's income of an amount formerly held by him in trust held not proven to have been erroneous, there being no proof that the distribution thereof was made to anyone else. 4. Fraud penalties held not sustained by the evidence.
1Opinion of the Court
OPINION.
Sternhagen:
The Commissioner determined the following deficiencies and penalties in the petitioner’s income taxes:
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For each of the four years in question the petitioner’s income has been increased by including the amounts of dividends upon shares of the Wolverine Bumper & Specialty Co. which the petitioner seeks to establish were shares owned by his wife as the result of a gift he made to her. The issue turns upon whether the evidence establishes that the alleged gift was made. Within this issue is a subsidiary question whether money received from the corporation in 1927…
2Cited by17 opinions
- Frank J. Valetti and Sarah J. Valetti v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1958
- Apt v. BirminghamDistrict Court, N.D. Iowa · 1950
- Estate of C.S. Brasington, Burns v. CommissionerUnited States Tax Court · 1953
- Bates v. CommissionerUnited States Tax Court · 1956
- Cooke v. CommissionerUnited States Tax Court · 1951
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