Varnell v. Commissioner
United States Board of Tax Appeals
Promised gift of stock held not completed until delivery of certificates; and dividends received before that time held taxable as a part of petitioner's income although by him divided with his daughters.
1Opinion of the Court
*233OPINION.
GOODRICH:
This is another case in which the question is, Who is the taxpayer? The income on which the tax is to be levied consists of the dividends paid upon the stock owned by petitioner’s wife at the time of her death and outstanding in her name until, at the time of final settlement of her estate, more than seven years afterwards, it was surrendered and reissued equally to petitioner and his two daughters. Petitioner contends that there should be included in his income, not the full amount of the dividends as respondent has determined, but only one third thereof, and that the…
2Cases cited8 opinions
- Brewster v. GageSupreme Court of the United States · 1930
- Hedrick v. CommissionerUnited States Board of Tax Appeals · 1931
- Dulin v. CommissionerUnited States Board of Tax Appeals · 1932
- Edson v. CommissionerUnited States Board of Tax Appeals · 1928
- Kuldell v. CommissionerUnited States Board of Tax Appeals · 1932
3 more not listed; retrieve them via the Exa API.
3Cited by6 opinions
- Apt v. BirminghamDistrict Court, N.D. Iowa · 1950
- Estate of DuBois v. CommissionerUnited States Tax Court · 1994
- McCann v. CommissionerUnited States Board of Tax Appeals · 1934
- Schoen v. CommissionerUnited States Board of Tax Appeals · 1934
- Schoen v. CommissionerUnited States Board of Tax Appeals · 1934
1 more not listed; retrieve them via the Exa API.