Braunstein v. Commissioner
United States Tax Court
Petitioners held a ticket in the Irish Sweepstakes. Two days prior to the running of the race, they received a notice of assignment of a horse. This assignment also notified petitioners that if their horse lost, they would nevertheless receive a certain small prize. The next day they set up trusts of portions of "any proceeds which may be obtained from said ticket." The assigned horse thereafter won the race.
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Petitioners held a ticket in the Irish Sweepstakes. Two days prior to the running of the race, they received a notice of assignment of a horse. This assignment also notified petitioners that if their horse lost, they would nevertheless receive a certain small prize. The next day they set up trusts of portions of "any proceeds which may be obtained from said ticket." The assigned horse thereafter won the race. Held: 1. A gift of the "proceeds" of an Irish Sweepstakes ticket prior to the race is tantamount to a gift of the ticket as such. 2. Donors of interests in the "proceeds" of a…
1Opinion of the Court
Henry Braunstein and Mae Braunstein v. Commissioner. Murray Kahn and Sylvia Kahn v. Commissioner.
Braunstein v. Commissioner
Docket Nos. 88049, 88050.
United States Tax Court
T.C. Memo 1962-210; 1962 Tax Ct. Memo LEXIS 99; 21 T.C.M. (CCH) 1132; T.C.M. (RIA) 62210;
August 31, 1962
Petitioners held a ticket in the Irish Sweepstakes. Two days prior to the running of the race, they received a notice of assignment of a horse. This assignment also notified petitioners that if their horse lost, they would nevertheless receive a certain small prize. The next day they set up trusts of portions of "any…
2Cases cited7 opinions
- Lucas v. EarlSupreme Court of the United States · 1930
- Helvering v. HorstSupreme Court of the United States · 1940
- Haverty Realty & Inv. Co. v. CommissionerUnited States Tax Court · 1944
- Droge v. CommissionerUnited States Board of Tax Appeals · 1937
- Riebe v. CommissionerUnited States Board of Tax Appeals · 1940
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