Rogers v. Commissioner
United States Board of Tax Appeals
1. In 1921 petitioners Tuthill and Thrall agreed to pay their mother an annuity of $16,000 per year in consideration of the transfer to them of stock having a fair market value considerably in excess of the purchase price of such an annuity.
Read the full summary
1. In 1921 petitioners Tuthill and Thrall agreed to pay their mother an annuity of $16,000 per year in consideration of the transfer to them of stock having a fair market value considerably in excess of the purchase price of such an annuity. Held, that the difference between the amount paid to the annuitant prior to her death and the fair market value of the stock at the time of transfer constitutes a gift, and that the basis for computing gain realized in the subsequent sale of the stock by the donees is the same as it would be in the hands of the donor. 2. The petitioners are not estopped…
1Opinion of the Court
MAY ROGERS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
HORACE S. TUTHILL, JR., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
EDNA MAY THRALL, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Rogers v. Commissioner
Docket Nos. 45051, 52448, 52449, 55546.
United States Board of Tax Appeals
31 B.T.A. 994; 1935 BTA LEXIS 1035;
January 9, 1935, Promulgated
1. In 1921 petitioners Tuthill and Thrall agreed to pay their mother an annuity of $16,000 per year in consideration of the transfer to them of stock having a fair market value considerably in excess of the…
2Cases cited28 opinions
- Brewster v. GageSupreme Court of the United States · 1930
- Philadelphia, Wilmington & Baltimore Railroad v. HowardSupreme Court of the United States · 1852
- Ray Consolidated Copper Co. v. United StatesSupreme Court of the United States · 1925
- United Press Ass'ns v. National Newspapers Ass'nCourt of Appeals for the Eighth Circuit · 1918
- Erskine v. CommissionerUnited States Board of Tax Appeals · 1932
23 more not listed; retrieve them via the Exa API.