Davies v. Commissioner
United States Tax Court
Intrafamily transfer by a nonresident alien of real property situated in the United States in return for a note secured by a mortgage, the face amount of which was less than the fair market value of the property, held, on the facts, to constitute a gift of an interest in property situated in the United States; held, further, gifts of cash abroad sufficient to retire the note, made without prearrangement in a later year, were not gifts of property situated in the United…
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Intrafamily transfer by a nonresident alien of real property situated in the United States in return for a note secured by a mortgage, the face amount of which was less than the fair market value of the property, held, on the facts, to constitute a gift of an interest in property situated in the United States; held, further, gifts of cash abroad sufficient to retire the note, made without prearrangement in a later year, were not gifts of property situated in the United States.
1Opinion of the Court
Geoffrey C. Davies, Petitioner, v. Commissioner of Internal Revenue, Respondent
Davies v. Commissioner
Docket No. 642-62
United States Tax Court
40 T.C. 525; 1963 U.S. Tax Ct. LEXIS 99;
June 14, 1963, Filed
Decision will be entered under Rule 50.
Intrafamily transfer by a nonresident alien of real property situated in the United States in return for a note secured by a mortgage, the face amount of which was less than the fair market value of the property, held, on the facts, to constitute a gift of an interest in property situated in the United States; held, further, gifts of cash abroad sufficient…
2Cases cited8 opinions
- Bartman v. CommissionerUnited States Tax Court · 1948
- Deal v. CommissionerUnited States Tax Court · 1958
- Story v. CommissionerUnited States Tax Court · 1962
- Tilles v. CommissionerUnited States Board of Tax Appeals · 1938
- Tilles v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1940
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