Thompson v. Commissioner
United States Board of Tax Appeals
The petitioner, who owned real estate in Kansas City, Missouri, made a gift of it in 1934 to a trustee for the benefit of her children. Her husband joined in the deed of conveyance. The petitioner returned it for gift tax purposes at the full value less an amount which it was estimated was the value of the husband's inchoate curtesy interest. The husband made a gift tax return of the estimated value of his inchoate curtesy interest.
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The petitioner, who owned real estate in Kansas City, Missouri, made a gift of it in 1934 to a trustee for the benefit of her children. Her husband joined in the deed of conveyance. The petitioner returned it for gift tax purposes at the full value less an amount which it was estimated was the value of the husband's inchoate curtesy interest. The husband made a gift tax return of the estimated value of his inchoate curtesy interest. The respondent has determined that the petitioner is liable to tax upon the entire value of the property. Held, that the petitioner is liable to gift tax upon the…
1Opinion of the Court
CORRELIA MASON THOMPSON, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Thompson v. Commissioner
Docket No. 86400.
United States Board of Tax Appeals
37 B.T.A. 793; 1938 BTA LEXIS 986;
April 29, 1938, Promulgated
The petitioner, who owned real estate in Kansas City, Missouri, made a gift of it in 1934 to a trustee for the benefit of her children. Her husband joined in the deed of conveyance. The petitioner returned it for gift tax purposes at the full value less an amount which it was estimated was the value of the husband's inchoate curtesy interest. The husband made a gift tax…
2Cases cited1 opinion
- Thompson v. CommissionerUnited States Board of Tax Appeals · 1938