Howard v. Commissioner
United States Tax Court
1. Held: That a property settlement agreement between petitioner's father and mother in 1930, whereby the beneficial interest in certain stock was transferred in trust for the benefit of petitioner and his brothers, was a taxable exchange. The basis to petitioner of a portion of such stock distributed to him in 1950 upon liquidation of the trust is determined accordingly.
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1. Held: That a property settlement agreement between petitioner's father and mother in 1930, whereby the beneficial interest in certain stock was transferred in trust for the benefit of petitioner and his brothers, was a taxable exchange. The basis to petitioner of a portion of such stock distributed to him in 1950 upon liquidation of the trust is determined accordingly. Sec. 113(a)(3), 1939 Code. 2. Held, that legal fees and other expenses incurred by petitioner in 1948 in connection with an official investigation into the artificial stimulation of certain horses owned by him were…
1Opinion of the Court
Robert S. Howard and Antoinette Lees Howard, Petitioners, v. Commissioner of Internal Revenue, Respondent
Howard v. Commissioner
Docket No. 62090
United States Tax Court
32 T.C. 1284; 1959 U.S. Tax Ct. LEXIS 79;
September 28, 1959, Filed
Decision will be entered under Rule 50.
1. Held: That a property settlement agreement between petitioner's father and mother in 1930, whereby the beneficial interest in certain stock was transferred in trust for the benefit of petitioner and his brothers, was a taxable exchange. The basis to petitioner of a portion of such stock distributed to him in 1950 upon…
Also in this document: Concurrence; Dissent.
2Cases cited9 opinions
- Johnson v. United StatesCourt of Appeals for the Ninth Circuit · 1943
- Rouse v. CommissionerUnited States Tax Court · 1946
- Walz v. CommissionerUnited States Board of Tax Appeals · 1935
- Rouse v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1947
- Archbold v. HelveringCourt of Appeals for the Second Circuit · 1940
4 more not listed; retrieve them via the Exa API.