Estate of Applestein v. Commissioner
United States Tax Court
In late December, P received word of the proposed merger of corporation A into corporation B. P, a stockholder in both corporations, purchased large amounts of shares in corporation A. The merger was approved by the shareholders on Feb. 7, 1973, and shortly before its effective date, P transferred some of these shares in A to brokerage accounts for his two children. These shares were subsequently exchanged as per the merger agreement.
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In late December, P received word of the proposed merger of corporation A into corporation B. P, a stockholder in both corporations, purchased large amounts of shares in corporation A. The merger was approved by the shareholders on Feb. 7, 1973, and shortly before its effective date, P transferred some of these shares in A to brokerage accounts for his two children. These shares were subsequently exchanged as per the merger agreement. Held: P is taxable on the gain resulting from the merger exchange. The transfers to the children's accounts represented anticipatory assignments of income. P…
1Opinion of the Court
Estate of Margita Applestein, Deceased, Louis Applestein, Administrator, and Louis Applestein, Surviving Husband, Petitioners v. Commissioner of Internal Revenue, Respondent
Estate of Applestein v. Commissioner
Docket No. 4788-79
United States Tax Court
80 T.C. 331; 1983 U.S. Tax Ct. LEXIS 120; 80 T.C. No. 10;
February 2, 1983, Filed
Decision will be entered for the respondent.
In late December, P received word of the proposed merger of corporation A into corporation B. P, a stockholder in both corporations, purchased large amounts of shares in corporation A. The merger was approved by the…
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