Hirst v. Commissioner
United States Tax Court
Transaction in which donee agreed to pay donor's gift taxes held not to result in realization of taxable income by donor measured by the excess of such gift taxes over donor's basis in the donated property. Richard H. Turner, 49 T.C. 356, affirmed 410 F.2d 752 (C.A. 6), followed; Joseph W. Johnson, Jr., 59 T.C. 791, affirmed 495 F. 2d 1079 (C.A. 6), certiorari denied 419 U.S. 1040, distinguished.
1Opinion of the Court
Edna Bennett Hirst, Petitioner v. Commissioner of Internal Revenue, Respondent
Hirst v. Commissioner
Docket No. 2865-72
United States Tax Court
63 T.C. 307; 1974 U.S. Tax Ct. LEXIS 13;
December 9, 1974, Filed
Decision will be entered for the petitioner.
Transaction in which donee agreed to pay donor's gift taxes held not to result in realization of taxable income by donor measured by the excess of such gift taxes over donor's basis in the donated property. Richard H. Turner, 49 T.C. 356, affirmed 410 F.2d 752 (C.A. 6), followed; Joseph W. Johnson, Jr., 59 T.C. 791, affirmed 495 F. 2d 1079 (C.A. 6),…
2Cases cited11 opinions
- Douglas v. WillcutsSupreme Court of the United States · 1935
- Johnson v. CommissionerUnited States Tax Court · 1973
- Turner v. CommissionerUnited States Tax Court · 1968
- Sheaffer v. CommissionerUnited States Tax Court · 1961
- Staley v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1943
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