Honnold v. Commissioner
United States Board of Tax Appeals
The petitioner and his wife, residents of California, jointly executed a declaration of trust on June 24, 1926, which acknowledged receipt from the petitioner of certain certificates of stock which are assumed to have been the property of the community.
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The petitioner and his wife, residents of California, jointly executed a declaration of trust on June 24, 1926, which acknowledged receipt from the petitioner of certain certificates of stock which are assumed to have been the property of the community. The declaration of trust further provided that in the discretion of the trustees (the grantor and his wife), the income or principal thereof should be devoted to, or accumulated for, charitable purposes and for the further purpose of paying an annuity to his wife if she survived him. There was reserved to the grantor and his wife, jointly, the…
1Opinion of the Court
OPINION.
Marquette :
The respondent has determined a deficiency in income tax for the year 1927 in the amount of $510,545.33. The petitioner asserts that the respondent has erred (1) in including in his gross income the income of “The Honnold Foundation,” including the income arising from the sales and exchanges of certain assets; (2) in computing the profit arising from such sales and exchanges; and (3) in denying him the right to deduct from his gross income donations made to the Foundation in the amount of $12,638.53. The second issue has been reserved for consideration until the first and…
2Cases cited34 opinions
- Reinecke v. Northern Trust Co.Supreme Court of the United States · 1929
- Tilden v. . GreenNew York Court of Appeals · 1891
- Estate of HinckleyCalifornia Supreme Court · 1881
- People ex rel. Ellert v. CogswellCalifornia Supreme Court · 1896
- Perkins v. Sunset Tel. and Tel. Co.California Supreme Court · 1909
29 more not listed; retrieve them via the Exa API.
3Cited by3 opinions
- Heller v. CommissionerUnited States Board of Tax Appeals · 1940
- Honnold v. CommissionerUnited States Board of Tax Appeals · 1934
- Patterson v. CommissionerUnited States Board of Tax Appeals · 1936