Legal Opinion

Bradford v. Commissioner

United States Tax Court

Decided September 16, 1960No. Docket No. 70401Published

Petitioner's substitution of her note for $ 205,000 for notes of her husband of equal amount held by a bank in 1938, held, on the facts not to constitute a taxable gift from petitioner to her husband in 1938.

1Opinion of the Court

Eleanor A. Bradford, Petitioner, v. Commissioner of Internal Revenue, Respondent

Bradford v. Commissioner

Docket No. 70401

United States Tax Court

34 T.C. 1059; 1960 U.S. Tax Ct. LEXIS 75;

September 16, 1960, Filed

Decision will be entered for the petitioner.

Petitioner's substitution of her note for $ 205,000 for notes of her husband of equal amount held by a bank in 1938, held, on the facts not to constitute a taxable gift from petitioner to her husband in 1938.

William Waller, Esq., and Lawrence Dortch, Esq., for the petitioner.

Jack D. Yarbrough, Esq., for the respondent.

Drennen, Judge.

DRENNEN

Respo…

2Cases cited15 opinions

  1. Estate of Sanford v. CommissionerSupreme Court of the United States · 1939
  2. Commissioner v. WemyssSupreme Court of the United States · 1945
  3. Smith v. ShaughnessySupreme Court of the United States · 1943
  4. Rosenthal v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1953
  5. Harrison v. CommissionerUnited States Tax Court · 1952

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