Jones v. Commissioner
United States Tax Court
In 1915 D made an inter vivos gift of certain securities to a trust which he established at the same time. Upon the death of the income beneficiary in 1953, T, who had a contingent interest in the remainder, received distribution of her share of those securities.
Read the full summary
In 1915 D made an inter vivos gift of certain securities to a trust which he established at the same time. Upon the death of the income beneficiary in 1953, T, who had a contingent interest in the remainder, received distribution of her share of those securities. Held, in computing gain upon disposition of the securities in 1969, T's basis must be determined with reference to their fair market value in 1915 rather than in 1953. Sec. 1015(c), I.R.C. 1954. Richard Archbold, 40 B.T.A. 1238, affirmed 115 F. 2d 1005 (C.A. 2), certiorari denied 313 U.S. 584, followed.
1Opinion of the Court
Laurence D. Jones and Olga Jones, Petitioners v. Commissioner of Internal Revenue, Respondent
Jones v. Commissioner
Docket No. 3026-72
United States Tax Court
61 T.C. 78; 1973 U.S. Tax Ct. LEXIS 37;
October 23, 1973, Filed
Decision will be entered under Rule 50.
In 1915 D made an inter vivos gift of certain securities to a trust which he established at the same time. Upon the death of the income beneficiary in 1953, T, who had a contingent interest in the remainder, received distribution of her share of those securities. Held, in computing gain upon disposition of the securities in 1969, T's basis…
2Cases cited31 opinions
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- United States v. CorrellSupreme Court of the United States · 1967
- Bingler v. JohnsonSupreme Court of the United States · 1969
- Brewster v. GageSupreme Court of the United States · 1930
- Sanford v. CommissionerUnited States Tax Court · 1968
26 more not listed; retrieve them via the Exa API.