Ginsberg v. Commissioner
United States Tax Court
Transferee Liability. -- The father of the petitioners, at a time when he was insolvent and liable for Federal income taxes, with intent to make valid gifts caused a corporation of which he was the sole stockholder to cancel his certificate of stock and reissue certificates in the names of his sons, the petitioners. One of the petitioners, Robert, signed the certificates as secretary of the corporation, and the stock was thereafter held by the attorney for the corporation.
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Transferee Liability. -- The father of the petitioners, at a time when he was insolvent and liable for Federal income taxes, with intent to make valid gifts caused a corporation of which he was the sole stockholder to cancel his certificate of stock and reissue certificates in the names of his sons, the petitioners. One of the petitioners, Robert, signed the certificates as secretary of the corporation, and the stock was thereafter held by the attorney for the corporation. The other petitioner, Donald, had not reached majority, was away from home at the times the certificates were issued, and…
1Opinion of the Court
Atkins, Judge:
The respondent determined that each petitioner is liable to the extent of $7,400, plus interest, as transferee of assets of his father and mother, Allen and Bess Ginsberg, for deficiencies in income taxes and additions thereto determined by the respondent against the transferors for the taxable years 1943 through 1945 as follows:
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FINDINGS OF FACT.
Some of the facts are stipulated and are incorporated herein by this reference.
The petitioners are the sons of Allen and Bess Ginsberg, and are residents of the Borough of Brooklyn, New York City.
The above liabilities of…
2Cases cited13 opinions
- Commissioner v. SternSupreme Court of the United States · 1958
- Beaver v. . BeaverNew York Court of Appeals · 1889
- Gobins v. Comm'rUnited States Tax Court · 1952
- In re the Estate of BabcockNew York Surrogate's Court · 1914
- Noell v. CommissionerUnited States Tax Court · 1955
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3Cited by35 opinions
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