Sharp v. Commissioner
United States Board of Tax Appeals
1. Dividends declared on corporate stock before, but payable at a time after, the death of a stockholder, held, includable in the gross estate of the deceased stockholder for estate tax purposes. 2. Proceeds of an insurance policy in which no right of substitution of the beneficiary is reserved, but in which the insured has the right to surrender the policy and receive cash therefor, or to pledge it for loans equal to the surrender value, and in which the estate of the…
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1. Dividends declared on corporate stock before, but payable at a time after, the death of a stockholder, held, includable in the gross estate of the deceased stockholder for estate tax purposes. 2. Proceeds of an insurance policy in which no right of substitution of the beneficiary is reserved, but in which the insured has the right to surrender the policy and receive cash therefor, or to pledge it for loans equal to the surrender value, and in which the estate of the insured shall be the beneficiary, if the named beneficiary fails to survive the insured, held, includable in the gross estate…
1Opinion of the Court
*539OPINION.
Seawell.
1. At the time of his death decedent had 5,012 shares of the Stephen F. Whitman & Son, Inc., class A stock. Under a stockholder’s pooling agreement outstanding, certain parties to the agreement had the right to purchase the stock at its book value, which was ascertained to be $123.11 per share. At this value it was sold by petitioners and included by them in the estate tax return. This value, however, did not include an 8 percent dividend declared on the stock on March 1, 1926, payable March 15, 1926. The right to the dividend was a property right and belonged to decedent’s…
2Cases cited7 opinions
- United States v. WellsSupreme Court of the United States · 1931
- Chase National Bank v. United StatesSupreme Court of the United States · 1929
- Ballinger v. CommissionerUnited States Board of Tax Appeals · 1931
- Hancy v. CommissionerUnited States Board of Tax Appeals · 1929
- Degener v. CommissionerUnited States Board of Tax Appeals · 1932
2 more not listed; retrieve them via the Exa API.
3Cited by3 opinions
- Golden v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1940
- Golden v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1940
- Sharp v. CommissionerUnited States Board of Tax Appeals · 1934