Miller v. Commissioner
United States Tax Court
1. In 1935 and 1936 petitioner and his parents gave to petitioner's minor son 12,500 shares of X corporation stock. Certificates representing this stock were issued by X in the name of petitioner's son, but were not delivered because X would deliver the stock only to the minor's legal guardian. In 1938 petitioner was appointed such guardian and stock certificates were issued and delivered to him as guardian.
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1. In 1935 and 1936 petitioner and his parents gave to petitioner's minor son 12,500 shares of X corporation stock. Certificates representing this stock were issued by X in the name of petitioner's son, but were not delivered because X would deliver the stock only to the minor's legal guardian. In 1938 petitioner was appointed such guardian and stock certificates were issued and delivered to him as guardian. In the same year petitioner and his wife, in anticipation of a divorce, executed an agreement in which petitioner agreed to pay $ 5,000 a year out of the income from this stock to his…
1Opinion of the Court
Lawrence Miller, Petitioner, v. Commissioner of Internal Revenue, Respondent
Miller v. Commissioner
Docket No. 106600
United States Tax Court
2 T.C. 285; 1943 U.S. Tax Ct. LEXIS 110;
June 29, 1943, Promulgated
Decision will be entered for petitioner.
1. In 1935 and 1936 petitioner and his parents gave to petitioner's minor son 12,500 shares of X corporation stock. Certificates representing this stock were issued by X in the name of petitioner's son, but were not delivered because X would deliver the stock only to the minor's legal guardian. In 1938 petitioner was appointed such guardian and stock…
2Cases cited7 opinions
- Helvering v. StuartSupreme Court of the United States · 1942
- Douglas v. WillcutsSupreme Court of the United States · 1935
- Helvering v. FitchSupreme Court of the United States · 1940
- Helvering v. LeonardSupreme Court of the United States · 1940
- Helvering v. FullerSupreme Court of the United States · 1940
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