Legal Opinion

Gobins v. Comm'r

United States Tax Court

Decided September 29, 1952No. Docket No. 26572Published

1. Jelwan, the taxpayer, transferred all or substantially all of his property to petitioner in fraud of creditors and in partial consideration for petitioner's promise of future support. By reason of such transfer, respondent determined that petitioner was liable as transferee of Jelwan's property for a deficiency in income tax, an addition to tax for fraud, and interest.

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1. Jelwan, the taxpayer, transferred all or substantially all of his property to petitioner in fraud of creditors and in partial consideration for petitioner's promise of future support. By reason of such transfer, respondent determined that petitioner was liable as transferee of Jelwan's property for a deficiency in income tax, an addition to tax for fraud, and interest. Jelwan was a diabetic and, at the time of the transfers, was in the hospital where his remaining leg was amputated. Petitioner expended from the money received certain sums in constructing and furnishing an apartment in the…

1Opinion of the Court

Fada Gobins, Petitioner, v. Commissioner of Internal Revenue, Respondent

Gobins v. Comm'r

Docket No. 26572

United States Tax Court

18 T.C. 1159; 1952 U.S. Tax Ct. LEXIS 89;

September 29, 1952, Promulgated

Decision will be entered under Rule 50.

1. Jelwan, the taxpayer, transferred all or substantially all of his property to petitioner in fraud of creditors and in partial consideration for petitioner's promise of future support. By reason of such transfer, respondent determined that petitioner was liable as transferee of Jelwan's property for a deficiency in income tax, an addition to tax for fraud,…

2Cases cited24 opinions

  1. Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
  2. Halle v. CommissionerUnited States Tax Court · 1946
  3. Halle v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1949
  4. Massachusetts v. United StatesSupreme Court of the United States · 1948
  5. Price v. United StatesSupreme Court of the United States · 1926

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