Friedmann v. Commissioner
United States Tax Court
While a suit for divorce was pending in Wisconsin petitioner and his wife entered into a written stipulation in which they settled their property rights and agreed that the wife was to have the custody of their two minor daughters. As a part of the property settlement petitioner agreed to transfer certain property in trust for the benefit of his wife and children.
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While a suit for divorce was pending in Wisconsin petitioner and his wife entered into a written stipulation in which they settled their property rights and agreed that the wife was to have the custody of their two minor daughters. As a part of the property settlement petitioner agreed to transfer certain property in trust for the benefit of his wife and children. This trust property included certain shares of preferred stock in a corporation of which petitioner was president. In the trust agreement it was provided that if the dividends on the stock did not equal a given amount petitioner…
1Opinion of the Court
OPINION.
Black, Judge-.
Petitioner seeks tbe redetermination of deficiencies in income tax determined against bim by the respondent for the calendar years 1935. 1936, and 1937 in tbe amounts of $3,097.85, $5,402.82, and $6,798.82, respectively.
In a statement attached to the deficiency notice tbe respondent adjusted petitioner’s net income as disclosed by his return for each of the taxable years 1935,1936 and 1937 by adding thereto the respective amounts of $16,311.00, $16,609.07, and $16,953.25, which he labeled “Income from trust” and explained as follows:
It is held that the income from the…
2Cases cited9 opinions
- Helvering v. CliffordSupreme Court of the United States · 1940
- Helvering v. StuartSupreme Court of the United States · 1942
- Douglas v. WillcutsSupreme Court of the United States · 1935
- Helvering v. FitchSupreme Court of the United States · 1940
- Helvering v. LeonardSupreme Court of the United States · 1940
4 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Friedmann v. CommissionerUnited States Tax Court · 1944