Legal Opinion

Carson Estate Co. v. Commissioner

United States Board of Tax Appeals

Decided November 15, 1934No. Docket Nos. 47444, 53489Published

Where a corporation issued to petitioner certificates of ownership purporting to evidence a sale of the corporation's title and interest, to a specified extent, in municipal bonds, the interest on which was exempt from income tax, deposited with a trustee under a trust agreement, which instruments, construed as a whole, indicated a transfer of beneficial ownership in the bonds was intended and effected, and not a loan, held, that petitioner became the beneficial owner of…

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Where a corporation issued to petitioner certificates of ownership purporting to evidence a sale of the corporation's title and interest, to a specified extent, in municipal bonds, the interest on which was exempt from income tax, deposited with a trustee under a trust agreement, which instruments, construed as a whole, indicated a transfer of beneficial ownership in the bonds was intended and effected, and not a loan, held, that petitioner became the beneficial owner of such bonds, and the interest it received, through the trustee, was in payment of interest on those bonds and therefore…

1Opinion of the Court

CARSON ESTATE COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Carson Estate Co. v. Commissioner

Docket Nos. 47444, 53489.

United States Board of Tax Appeals

31 B.T.A. 607; 1934 BTA LEXIS 1059;

November 15, 1934, Promulgated

Where a corporation issued to petitioner certificates of ownership purporting to evidence a sale of the corporation's title and interest, to a specified extent, in municipal bonds, the interest on which was exempt from income tax, deposited with a trustee under a trust agreement, which instruments, construed as a whole, indicated a transfer of beneficial…

2Cases cited1 opinion

  1. Carson Estate Co. v. CommissionerUnited States Board of Tax Appeals · 1934

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