Autin v. Commissioner
United States Tax Court
L, a Louisiana corporation, was incorporated during 1974 because P wanted to help his son, S, become involved in business. One hundred shares of L stock were issued at L's incorporation, of which P received 51 shares and S received 49 shares.
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L, a Louisiana corporation, was incorporated during 1974 because P wanted to help his son, S, become involved in business. One hundred shares of L stock were issued at L's incorporation, of which P received 51 shares and S received 49 shares. At the time L was incorporated, P executed a "counter letter" which stated that P renounced any ownership interest in the 51 shares of stock issued to him and that the 51 shares had been acquired by P on account of S. From the time of L's incorporation until June 1988, P held himself out as the majority shareholder of L to the IRS, the Louisiana taxing…
1Opinion of the Court
Wells, Judge:
Respondent determined a deficiency in petitioner’s Federal gift tax in the amount of $1,649,736 and an addition to tax under section 6651(a)(1) of $412,434. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.
The issues for decision are: (1) Whether the change of record ownership of stock in Louisiana International Marine, Inc., from petitioner to his son during June 1988 was a transfer of property that constituted a gift for Federal gift…
2Cases cited23 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- United States v. BoyleSupreme Court of the United States · 1985
- Higgins v. SmithSupreme Court of the United States · 1940
- Morgan v. CommissionerSupreme Court of the United States · 1940
18 more not listed; retrieve them via the Exa API.
3Cited by3 opinions
- Estate of Trenchard v. CommissionerUnited States Tax Court · 1995
- Autin v. CommissionerUnited States Tax Court · 1994
- Estate of Fox v. CommissionerUnited States Tax Court · 1995