Legal Opinion
Horst v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided November 13, 1939No. 83PublishedCited by 11 opinions
1Opinion of the Court
PATTERSON, Circuit Judge.
The question is whether a taxpayer who detaches coupons from bonds owned by him and delivers them to another as a gift prior' to the time when the coupons are payable is liable for income tax on the amounts later collected on the coupons by the transferee.
The petitioner owned a number of coupon bonds. The coupons represented the interest on the bonds and were payable to bearer. In 1934 he detached unmatured coupons of face value of $25,182.-50 and transferred them by manual delivery to his son as a gift. The coupons matured later on in the same year, and the son…
2Cases cited12 opinions
- Lucas v. EarlSupreme Court of the United States · 1930
- Corliss v. BowersSupreme Court of the United States · 1930
- Blair v. CommissionerSupreme Court of the United States · 1937
- Burnet v. LeiningerSupreme Court of the United States · 1932
- Reinecke v. SmithSupreme Court of the United States · 1933
7 more not listed; retrieve them via the Exa API.
3Cited by11 opinions
- Helvering v. HorstSupreme Court of the United States · 1940
- Galt v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1954
- Galt v. CommissionerUnited States Tax Court · 1953
- Eubank v. CommissionerCourt of Appeals for the Second Circuit · 1940
- Brown v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1940
6 more not listed; retrieve them via the Exa API.