Legal Opinion

Hiatt v. Commissioner

United States Board of Tax Appeals

Decided April 21, 1931No. Docket No. 27081PublishedCited by 1 opinion

Where a mother makes a valid transfer of leasehold interests in her land to her daughters and the daughters later sell such interests, the income resulting from such sales is not taxable to her.

1Opinion of the Court

*1247OPINION.

Lansdon:

The respondent has determined the deficiency here involved on the theory that the leases in question were the property of this petitioner and that, therefore, any income resulting from the sales thereof is taxable to her. The petitioner contends that by the execution of certain instruments in the form of oil and gas leases to her daughters prior to the sale of such leases to operating companies her daughters Nora A. Hiatt and Lulu B. Hiatt became the absolute owners of such leases and, therefore, the recipients of any income resulting from the sales thereof.

Lulu B. and Nora A.…

2Cases cited3 opinions

  1. Stallings v. NewtonSupreme Court of Georgia · 1900
  2. Waynick v. RichmondSupreme Court of Kansas · 1873
  3. Jones v. KerrSupreme Court of Kansas · 1898

3Cited by1 opinion

  1. Hiatt v. CommissionerUnited States Board of Tax Appeals · 1931

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