Lammerding v. Commissioner
United States Board of Tax Appeals
In the taxable year corporate stock was transferred into petitioners' names upon the corporate records by the husband and father of the respective petitioners, in satisfaction of and pursuant to an earlier understanding with him that in return for moneys loaned him they would receive interest and participate in the proceeds of the investment of the money loaned.
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In the taxable year corporate stock was transferred into petitioners' names upon the corporate records by the husband and father of the respective petitioners, in satisfaction of and pursuant to an earlier understanding with him that in return for moneys loaned him they would receive interest and participate in the proceeds of the investment of the money loaned. The certificates of stock were retained by the father until 1936, but no other exercise by him of dominion over the stock is shown. The father had in the previous year decided to set the corporate stock aside for petitioners, and had…
1Opinion of the Court
*590OPINION.
Disney:
These proceedings involve determinations of deficiencies in income tax of the petitioners, residents of New Jersey, for the year 1934.
The cases were consolidated for hearing.
None of the petitioners filed any Federal income tax return for the taxable year 1934. However, after Walter H. Hildick discussed with a revenue agent of the Commissioner tax liability of petitioners for 1934, and with a view to settling their tax liability, petitioners filed waivers of restrictions on assessment and collection of deficiency in tax for the taxable year ended December 31, 1934. Thereafter…
2Cases cited6 opinions
- Hatch v. Oil Co.Supreme Court of the United States · 1879
- Chester Glass Co. v. DeweyMassachusetts Supreme Judicial Court · 1819
- Reed v. RobertsSupreme Court of Pennsylvania · 1877
- Phillips v. PlastridgeSupreme Court of Vermont · 1935
- Hammer v. United StatesCourt of Appeals for the Second Circuit · 1918
1 more not listed; retrieve them via the Exa API.
3Cited by8 opinions
- Apt v. BirminghamDistrict Court, N.D. Iowa · 1950
- Baltimore v. CommissionerUnited States Tax Court · 1958
- Estate of Walter Blair Roddenbery v. CommissionerUnited States Tax Court · 1949
- Heller v. CommissionerUnited States Board of Tax Appeals · 1940
- J. W. Hughes v. CommissionerUnited States Tax Court · 1945
3 more not listed; retrieve them via the Exa API.