Coffey v. Commissioner
United States Tax Court
The taxpayer endorsed stock certificates for transfer to his minor children with the declaration, in the presence of a witness, that he was making a gift of the shares to the children.
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The taxpayer endorsed stock certificates for transfer to his minor children with the declaration, in the presence of a witness, that he was making a gift of the shares to the children. He kept the certificates in his possession, did not have the shares transferred to the children on the books of the corporations, and continued to receive the dividends on the shares for his own use, without any accounting to the children prior to the taxable year 1938. Held, that there were no valid gifts of the shares to the children.
1Opinion of the Court
R. C. Coffey, Petitioner, v. Commissioner of Internal Revenue, Respondent
Coffey v. Commissioner
Docket No. 105452
United States Tax Court
1 T.C. 579; 1943 U.S. Tax Ct. LEXIS 236;
February 12, 1943, Promulgated
Decision will be entered under Rule 50.
The taxpayer endorsed stock certificates for transfer to his minor children with the declaration, in the presence of a witness, that he was making a gift of the shares to the children. He kept the certificates in his possession, did not have the shares transferred to the children on the books of the corporations, and continued to receive the dividends…
2Cases cited12 opinions
- Basket v. HassellSupreme Court of the United States · 1883
- In re Estate of SoulardSupreme Court of Missouri · 1897
- Allen-West Commission Co. v. GrumblesCourt of Appeals for the Eighth Circuit · 1904
- Coffey v. CommissionerUnited States Tax Court · 1943
- In Re Bauernschmidt's EstateCourt of Appeals of Maryland · 1903
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