Rainger v. Commissioner
United States Tax Court
1. Decedent transferred all funds held as community property to the separate bank account of his wife in order to avoid his own generosity in making unfortunate loans and injudicious investments.
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1. Decedent transferred all funds held as community property to the separate bank account of his wife in order to avoid his own generosity in making unfortunate loans and injudicious investments. Since there was no agreement to transmute community property to separate property, held, management and control of the property by the wife is insufficient, standing alone, to effect such transmutation. 2. A decree of the state court in inheritance tax proceedings purporting to decide that community property was transmuted to separate property of the husband and wife held as tenants in common, held,…
1Opinion of the Court
Estate of Ralph Rainger, Deceased, Elizabeth Rainger, Executrix, Petitioner, v. Commissioner of Internal Revenue, Respondent
Rainger v. Commissioner
Docket No. 8995
United States Tax Court
12 T.C. 483; 1949 U.S. Tax Ct. LEXIS 234;
March 30, 1949, Promulgated
Decision will be entered under Rule 50.
1. Decedent transferred all funds held as community property to the separate bank account of his wife in order to avoid his own generosity in making unfortunate loans and injudicious investments. Since there was no agreement to transmute community property to separate property, held, management and control…
2Cases cited12 opinions
- Blair v. CommissionerSupreme Court of the United States · 1937
- Freuler v. HelveringSupreme Court of the United States · 1934
- Fernandez v. WienerSupreme Court of the United States · 1946
- Kaltschmidt v. WeberCalifornia Supreme Court · 1904
- Green v. CommissionerUnited States Tax Court · 1946
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