Legal Opinion
Johnson v. Commissioner of Internal Revenue
Court of Appeals for the Sixth Circuit
Decided April 9, 1974No. Nos. 73-1908-73-1910PublishedCited by 9 opinions
1Opinion of the Court
CELEBREZZE, Circuit Judge.
This case presents the question of a donor’s income tax liability upon the transfer to a trust of highly appreciated stock subject to debt, where the proceeds of a loan which the stock secures are received by the donor and a large portion of the proceeds is used to pay the donor’s gift taxes on the transfer.
Joseph W. Johnson, David F. S. Johnson, and H. Clay Evans Johnson1 developed Interstate Life and Accident Insurance Company into a successful enterprise. In March 1965, each taxpayer decided to give a substantial block of Interstate stock to his children. Dr.…
2Cases cited30 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Old Colony Trust Co. v. CommissionerSupreme Court of the United States · 1929
- Crane v. CommissionerSupreme Court of the United States · 1947
- Kimbell-Diamond Milling Co. v. Comm'rUnited States Tax Court · 1950
25 more not listed; retrieve them via the Exa API.
3Cited by9 opinions
- Guest v. CommissionerUnited States Tax Court · 1981
- Estate of Henry v. CommissionerUnited States Tax Court · 1978
- Cottage Savings Association v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1990
- Edna Bennett Hirst v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1978
- Edna Bennett Hirst v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1978
4 more not listed; retrieve them via the Exa API.