Alvord v. Commissioner
United States Tax Court
1. Patenotre owned 95 per cent of the shares of Hekor, a Canadian corporation, whose assets consisted of securities held for its account in New York City by Hutton & Co. On September 29, 1949, Patenotre assigned the 9,500 shares to the Treasury as security for substantial tax liabilities of his and his mother's for the years 1931 to 1949, inclusive, in consideration for tax clearance to leave the United States.
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1. Patenotre owned 95 per cent of the shares of Hekor, a Canadian corporation, whose assets consisted of securities held for its account in New York City by Hutton & Co. On September 29, 1949, Patenotre assigned the 9,500 shares to the Treasury as security for substantial tax liabilities of his and his mother's for the years 1931 to 1949, inclusive, in consideration for tax clearance to leave the United States. On October 26, 1949, Patenotre agreed to assign at some future date the 9,500 shares to petitioner, a United States citizen "free and clear of any prior liabilities and assignment" for…
1Opinion of the Court
Ellsworth C. Alvord and Katharyn W. Alvord, Petitioners, v. Commissioner of Internal Revenue, Respondent
Alvord v. Commissioner
Docket Nos. 62747, 64407
United States Tax Court
32 T.C. 1; 1959 U.S. Tax Ct. LEXIS 203;
April 3, 1959, Filed
Decisions will be entered for the respondent.
1. Patenotre owned 95 per cent of the shares of Hekor, a Canadian corporation, whose assets consisted of securities held for its account in New York City by Hutton & Co. On September 29, 1949, Patenotre assigned the 9,500 shares to the Treasury as security for substantial tax liabilities of his and his mother's for the…
2Cases cited8 opinions
- Helvering v. Northwest Steel Rolling Mills, Inc.Supreme Court of the United States · 1940
- Marsman v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1953
- Marsman v. CommissionerUnited States Tax Court · 1952
- Eder v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1943
- Eder v. CommissionerUnited States Board of Tax Appeals · 1942
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