Horst v. Commissioner
United States Board of Tax Appeals
The owner of foreign state, municipal, and industrial coupon bonds, clipped therefrom and delivered before maturity to another, as a gift, negotiable interest coupons having a maturity within the taxable year. Payments were received on the coupons by the donee within the taxable year. The donor was the owner of the bonds throughout the taxable year and kept his books and made his income tax returns on the cash receipts and disbursements basis.
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The owner of foreign state, municipal, and industrial coupon bonds, clipped therefrom and delivered before maturity to another, as a gift, negotiable interest coupons having a maturity within the taxable year. Payments were received on the coupons by the donee within the taxable year. The donor was the owner of the bonds throughout the taxable year and kept his books and made his income tax returns on the cash receipts and disbursements basis. Held, that the amounts received by the donee on the coupons were taxable income to the donor.
1Opinion of the Court
PAUL R. G. HORST, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Horst v. Commissioner
Docket Nos. 90819, 93220.
United States Board of Tax Appeals
39 B.T.A. 757; 1939 BTA LEXIS 987;
April 12, 1939, Promulgated
The owner of foreign state, municipal, and industrial coupon bonds, clipped therefrom and delivered before maturity to another, as a gift, negotiable interest coupons having a maturity within the taxable year. Payments were received on the coupons by the donee within the taxable year. The donor was the owner of the bonds throughout the taxable year and kept his books and made…
2Cases cited9 opinions
- Corliss v. BowersSupreme Court of the United States · 1930
- Reinecke v. Northern Trust Co.Supreme Court of the United States · 1929
- Chase National Bank v. United StatesSupreme Court of the United States · 1929
- Saltonstall v. SaltonstallSupreme Court of the United States · 1928
- Horst v. CommissionerUnited States Board of Tax Appeals · 1939
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