Staley v. Commissioner
United States Board of Tax Appeals
1. In 1927 petitioner Augustus E. Staley informed some of his children of an intention to give them a portion of his holdings of stock in the A. E. Staley Manufacturing Co. No transfers were made at that time because of marital difficulties several of the children were then having. In 1934, after these difficulties were adjusted, petitioner irrevocably transferred certain shares of the stock, in trust, for the benefit of each of his children.
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1. In 1927 petitioner Augustus E. Staley informed some of his children of an intention to give them a portion of his holdings of stock in the A. E. Staley Manufacturing Co. No transfers were made at that time because of marital difficulties several of the children were then having. In 1934, after these difficulties were adjusted, petitioner irrevocably transferred certain shares of the stock, in trust, for the benefit of each of his children. From the time of his declaration to make the gift and the transfer of the stock in trust, the donor continued to be the record owner of the stock, held…
1Opinion of the Court
Disney:
These proceedings were consolidated for hearing and report, and involve the redetermination of deficiencies in gift taxes for the year 1934, the amount being $456,277.50 in Docket No. 88772 and $27,793.98 in Docket No. 88773. The issues common to both proceedings are whether completed gifts were made in the taxable year and, if so, the value of the stocks involved in the gifts. The findings of fact upon each issue will be followed by the opinion thereon.
FINDINGS OF FACT UPON FIRST ISSUE.
The petitioners are residents of Decatur, Illinois. Prior to 1927 Augustus E. Staley, the petitioner…
2Cases cited5 opinions
- Burnet v. GuggenheimSupreme Court of the United States · 1933
- Virginia v. West VirginiaSupreme Court of the United States · 1915
- Richards v. WilsonIndiana Supreme Court · 1916
- Estate of Beatty v. Western College of ToledoIllinois Supreme Court · 1898
- Northern Trust Co. v. SwartzIllinois Supreme Court · 1923
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- White Farm Equipment Co. v. CommissionerUnited States Tax Court · 1973
- South Carolina National Bank v. McLeodDistrict Court, D. South Carolina · 1966
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