Schuhmacher v. Commissioner
United States Tax Court
1. Value of shares of corporate stock for gift tax purposes and estate tax purposes determined. 2. Gifts of shares of corporate stock were made to five minor grandchildren, with the provision that the stock should be issued in the names of their respective fathers and held by them as guardians until such time as each grandchild became 21 years of age, the dividends to be accumulated or used only for the benefit of the various grandchildren without any benefit ever inuring to…
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1. Value of shares of corporate stock for gift tax purposes and estate tax purposes determined. 2. Gifts of shares of corporate stock were made to five minor grandchildren, with the provision that the stock should be issued in the names of their respective fathers and held by them as guardians until such time as each grandchild became 21 years of age, the dividends to be accumulated or used only for the benefit of the various grandchildren without any benefit ever inuring to the respective fathers, except that the fathers had the right to vote such stock. Held, that the gifts were of future…
1Opinion of the Court
OPINION.
Turner, Jvdge:
The shares of common stock in the Schuhmacher Co. included in the gross estates of Henry C. Schuhmacher and Julia Agnes Robson, respectively, as well as the shares that were the subject of gifts by Mrs. Schuhmacher, were reported as having a value of $22 a share on the respective critical dates. By amended petitions and on brief, the petitioners respectively allege that the value of the respective blocks of the stock on the critical dates was not in excess of $18 per share. The respondent contends that the value of the stock included in the estate of Henry C. Schuhmacher…
2Cases cited8 opinions
- United States v. PelzerSupreme Court of the United States · 1941
- Fondren v. CommissionerSupreme Court of the United States · 1945
- Commissioner v. DisstonSupreme Court of the United States · 1945
- Ryerson v. United StatesSupreme Court of the United States · 1941
- Lovejoy v. CockrellTexas Commission of Appeals · 1933
3 more not listed; retrieve them via the Exa API.
3Cited by3 opinions
- Lockard v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1948
- English v. United StatesDistrict Court, N.D. Florida · 1968
- Schuhmacher v. CommissionerUnited States Tax Court · 1947