Legal Opinion

Insull v. Commissioner

United States Board of Tax Appeals

Decided February 14, 1935No. Docket Nos. 68001-68003, 68503-68505Published

1. In computing the deduction allowable for charitable contributions made during the years 1929 and 1930 the taxpayers' net incomes are inclusive of capital gains. Helvering v. Bliss,293 U.S. 144. 2. In 1929 the petitioners exchanged certain securities for shares of stock of Insull Utility Investments, Inc., and immediately after the transfer were in control of the corporation.

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1. In computing the deduction allowable for charitable contributions made during the years 1929 and 1930 the taxpayers' net incomes are inclusive of capital gains. Helvering v. Bliss,293 U.S. 144. 2. In 1929 the petitioners exchanged certain securities for shares of stock of Insull Utility Investments, Inc., and immediately after the transfer were in control of the corporation. Held, that the exchange of securities for shares of stock of Insull Utility Investments, Inc., constituted a nontaxable exchange. 3. At the time of the exchange above referred to the petitioners received rights to…

1Opinion of the Court

SAMUEL INSULL, JR., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

MARGARET A. INSULL, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

SAMUEL INSULL, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Insull v. Commissioner

Docket Nos. 68001-68003, 68503-68505.

United States Board of Tax Appeals

32 B.T.A. 47; 1935 BTA LEXIS 1003;

February 14, 1935, Promulgated

1. In computing the deduction allowable for charitable contributions made during the years 1929 and 1930 the taxpayers' net incomes are inclusive of capital gains. Helvering v. Bliss,293 U.S. 144.

2. In 1929…

2Cases cited2 opinions

  1. Helvering v. BlissSupreme Court of the United States · 1934
  2. Insull v. CommissionerUnited States Board of Tax Appeals · 1935

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