Irvine v. Commissioner
United States Board of Tax Appeals
A husband transferred substantially all of his property to himself and wife as joint tenants with right of survivorship and not as tenants in common. He died May 14, 1932, leaving an estate insufficient to meet a deficiency in income tax for 1929, although his interest in the jointly owned property at date of death was far in excess of such deficiency.
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A husband transferred substantially all of his property to himself and wife as joint tenants with right of survivorship and not as tenants in common. He died May 14, 1932, leaving an estate insufficient to meet a deficiency in income tax for 1929, although his interest in the jointly owned property at date of death was far in excess of such deficiency. A part of the husband's property was transferred to the joint tenancy prior to December 31, 1929, and a large part after that date. The value of the property placed in the joint tenancy after 1929 was several times the amount of the tax…
1Opinion of the Court
OPINION.
Smith:
This proceeding involves a proposed assessment against the petitioner as transferee of assets of her deceased husband for income taxes of the decedent for the calendar year 1929 in the amount of $2,728.05, plus interest.
During 1929 the petitioner’s husband, C. G. Irvine, a resident of Minneapolis, Minnesota, hereinafter referred to as the decedent, purchased from H. S. Byllesby & Co. a number of shares of stock in various corporations and had the stock certificates issued to himself and petitioner herein as “joint tenants with right of. survivorship and not as tenants in…
2Cases cited7 opinions
- United States v. AndersonSupreme Court of the United States · 1926
- Tyler v. United StatesSupreme Court of the United States · 1930
- Griswold v. HelveringSupreme Court of the United States · 1933
- Wilson v. WilsonSupreme Court of Minnesota · 1890
- United States v. RobertsonCourt of Appeals for the Seventh Circuit · 1910
2 more not listed; retrieve them via the Exa API.
3Cited by6 opinions
- Irvine v. HelveringCourt of Appeals for the Eighth Circuit · 1938
- Alonso v. CommissionerUnited States Tax Court · 1982
- Alonso v. CommissionerUnited States Tax Court · 1982
- Connell v. CommissionerUnited States Tax Court · 1992
- Irvine v. CommissionerUnited States Board of Tax Appeals · 1937
1 more not listed; retrieve them via the Exa API.