Holt v. Commissioner
United States Board of Tax Appeals
1. Value of certain corporate stocks determined. 2. Where a donor sets aside bonds for a donee, offers to hand or send them to her, but at her request retains possession of them, sending her the interest as paid, keeping the bonds separate and apart from donor's personal papers and securities, and for more than two and one-half years referring to the bonds as the donee's property, held, the donor was a voluntary trustee for the donee.
1Opinion of the Court
*567OPINION.
Marquette :
This proceeding involves five items of property. As to four of these items the question relates to valuation; as to the fifth we mu,st decide whether certain purported gifts actually divested the property from the decedent.
As to the two tracts of land owned by Holt, the Fort Smug Tract and the Dickey Tract, there is no controversy. The petitioners admit, and there is no evidence to contradict, the propriety and reasonableness of the figures determined by the respondent; and the valuations so determined of $60,000 and $11,000, respectively, will stand.
As for the 100 shares…
2Cases cited3 opinions
- Witherington v. Herring.Supreme Court of North Carolina · 1906
- Thomas v. . HoustonSupreme Court of North Carolina · 1921
- Blackburn v. . BlackburnSupreme Court of North Carolina · 1891
3Cited by7 opinions
- Ward v. CommissionerUnited States Tax Court · 1986
- Estate of Grossinger v. CommissionerUnited States Tax Court · 1982
- Blake v. CommissionerUnited States Board of Tax Appeals · 1931
- Estate of Harrington v. CommissionerUnited States Tax Court · 1943
- Estate of Selig Allen Grossinger, Deceased, Joseph G. Blum v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1983
2 more not listed; retrieve them via the Exa API.