Bradford v. Commissioner
United States Tax Court
Petitioner's substitution of her note for $ 205,000 for notes of her husband of equal amount held by a bank in 1938, held, on the facts not to constitute a taxable gift from petitioner to her husband in 1938.
1Opinion of the Court
Dkennen, Judge:
Respondent determined a deficiency in gift tax against petitioner and an addition to the tax under section 291, I.R.C. 1939, for the year 1938 in the respective amounts of $29,025 and $7,256.25. The deficiency and addition to tax were subsequently corrected to $14,850 and $3,712.50, respectively.
The single issue is whether petitioner’s substitution of her promissory note in the amount of $205,000 for notes of her husband held by a bank in 1938 constituted a taxable gift to her husband in the amount of $205,000 in the year 1938.
In a companion case, J. C. Bradford, Docket No.…
2Cases cited14 opinions
- Estate of Sanford v. CommissionerSupreme Court of the United States · 1939
- Commissioner v. WemyssSupreme Court of the United States · 1945
- Smith v. ShaughnessySupreme Court of the United States · 1943
- Rosenthal v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1953
- Harrison v. CommissionerUnited States Tax Court · 1952
9 more not listed; retrieve them via the Exa API.
3Cited by8 opinions
- Estate of Christ v. Comm'rUnited States Tax Court · 1970
- Weller v. CommissionerUnited States Tax Court · 1962
- Bradford v. CommissionerUnited States Tax Court · 1960
- Powe v. CommissionerUnited States Tax Court · 1966
- Bradford v. CommissionerUnited States Tax Court · 1960
3 more not listed; retrieve them via the Exa API.