Dix v. Commissioner
United States Tax Court
On June 20, 1960, Janet D. Dix, then 79 years of age and in good health, transferred to her three children, John and George Dix, and Elizabeth Keyes, securities having a fair market value of $ 162,689.75 in return for the children's promise to pay their mother $ 22,452 annually in semiannual installments of $ 11,226. No part of the transfer from the mother represented a gift to her children.
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On June 20, 1960, Janet D. Dix, then 79 years of age and in good health, transferred to her three children, John and George Dix, and Elizabeth Keyes, securities having a fair market value of $ 162,689.75 in return for the children's promise to pay their mother $ 22,452 annually in semiannual installments of $ 11,226. No part of the transfer from the mother represented a gift to her children. During 1960 John and George each made payments to their mother pursuant to said agreement of $ 4,000. Upon receipt of the securities and before any payments had been made to the mother, the children sold…
1Opinion of the Court
Aeundell, Judge:
Respondent determined deficiencies in income tax for the calendar year 1960 in these consolidated proceedings in the amounts of $4,577.49 and $6,487.62, respectively. Petitioners contend that instead of deficiencies they are entitled to refunds of $474.45 and $796.82, respectively.
Petitioners have assigned two errors, as follows:(a) In determining the taxable income of the Petitioners for 'the year 1960 the Commissioner erroneously determined that the basis of stock owned one-third by John C. W. Dix [George E. Dix], which was sold for $121,095.00, was $84,514.39.(b) The…
2Cases cited12 opinions
- Reliable Incubator & Brooder Co. v. CommissionerUnited States Tax Court · 1946
- Klein v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1936
- Bartman v. CommissionerUnited States Tax Court · 1948
- Klein v. CommissionerUnited States Board of Tax Appeals · 1934
- James Richard Bowden v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1956
7 more not listed; retrieve them via the Exa API.
3Cited by23 opinions
- Vaira v. CommissionerUnited States Tax Court · 1969
- Edgar v. CommissionerUnited States Tax Court · 1971
- John C. W. Dix and Caroline W. Dix v. Commissioner of Internal Revenue, George E. Dix v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1968
- Siple v. CommissionerUnited States Tax Court · 1970
- Estate of Gribauskas v. CommissionerUnited States Tax Court · 2001
18 more not listed; retrieve them via the Exa API.