Legal Opinion
Schlegel v. United States
District Court, W.D. New York
Decided March 15, 1947No. Civ. No. 1842PublishedCited by 5 opinions
1Opinion of the Court
BURKE, District Judge.
On August 1, 1940 plaintiff made a gift to his daughter of 100 shares of Class B stock of Schlegel Manufacturing Company. On February 10, 1941 he made a gift to his wife of 680 shares of Class B stock of the same company. The latter gift was incorrectly reported in plaintiff’s gift tax return as a gift of 400 shares. The tax liability on the excess of 280 shares not reported is not involved in this action. In plaintiff’s gift tax returns the stock was valued at $220 per share. The Commissioner assessed deficiencies in each case on the ground that the fair value of the…
2Cases cited2 opinions
- Ray Consolidated Copper Co. v. United StatesSupreme Court of the United States · 1925
- Commissioner of Internal Revenue v. McCannCourt of Appeals for the Second Circuit · 1944
3Cited by5 opinions
- Worthen v. United StatesDistrict Court, D. Massachusetts · 1961
- Dibble v. Sumter Ice and Fuel Co.Court of Appeals of South Carolina · 1984
- Estate of Gillet v. Comm'rUnited States Tax Court · 1985
- Estate of Tompkins v. CommissionerUnited States Tax Court · 1961
- Dibble v. Sumter Ice and Fuel Co.Court of Appeals of South Carolina · 1984