Hunt v. Commissioner
United States Board of Tax Appeals
1. No profit was realized by the petitioner from the conveyance by him to his daughter in the year 1920 of certain real estate involved herein. 2. An allowance for the exhaustion, wear and tear of a certain building owned by the petitioner, computed at the rate of 2 per cent, held to be reasonable. 3. Amounts drawn by the petitioner in the years 1920 and 1921 from a corporation in which he held a controlling interest, held to constitute distributions of profits, and…
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1. No profit was realized by the petitioner from the conveyance by him to his daughter in the year 1920 of certain real estate involved herein. 2. An allowance for the exhaustion, wear and tear of a certain building owned by the petitioner, computed at the rate of 2 per cent, held to be reasonable. 3. Amounts drawn by the petitioner in the years 1920 and 1921 from a corporation in which he held a controlling interest, held to constitute distributions of profits, and therefore are taxable as dividends.
1Opinion of the Court
*559OPINION.
MaRquette:
The evidence shows that in the year 1920 the petitioner conveyed to his daughter certain real estate referred to in the findings of fact; that the conveyance was made to the daughter as a gift and that the petitioner received no consideration therefor in money or money’s worth. The petitioner, therefore, did not realize any profit from the transaction.
The evidence also shows that in the years 1913 and 1914 the petitioner erected a building in Tulsa, Okla. The petitioner and the respondent are in accord as to the cost of the building but do not agree as to the rate that…
2Cited by4 opinions
- Iverson v. CommissionerUnited States Board of Tax Appeals · 1934
- Weisberger v. CommissionerUnited States Board of Tax Appeals · 1933
- Hunt v. CommissionerUnited States Board of Tax Appeals · 1927
- Weisberger v. CommissionerUnited States Board of Tax Appeals · 1933