Miami Nat'l Bank v. Commissioner
United States Tax Court
C transferred certain stock of P, owned by him prior to such transfer, to a broker to be held in a subordinated securities account. Under the terms of such account, C retained some of the incidents of ownership, including the right to dividends and the right to vote the stock; but the broker acquired legal title to the stock, and it could be sold to satisfy the claims of creditors of the broker.
Read the full summary
C transferred certain stock of P, owned by him prior to such transfer, to a broker to be held in a subordinated securities account. Under the terms of such account, C retained some of the incidents of ownership, including the right to dividends and the right to vote the stock; but the broker acquired legal title to the stock, and it could be sold to satisfy the claims of creditors of the broker. While such account was in effect, C and other persons purported to sell to DL their stock in P, which constituted in excess of 80 percent of P's stock. Held, C was the beneficial owner of the stock…
1Opinion of the Court
Miami National Bank, Petitioner v. Commissioner of Internal Revenue, Respondent
Miami Nat'l Bank v. Commissioner
Docket No. 580-74
United States Tax Court
67 T.C. 793; 1977 U.S. Tax Ct. LEXIS 156;
February 14, 1977, Filed
Decision will be entered under Rule 155.
C transferred certain stock of P, owned by him prior to such transfer, to a broker to be held in a subordinated securities account. Under the terms of such account, C retained some of the incidents of ownership, including the right to dividends and the right to vote the stock; but the broker acquired legal title to the stock, and it could be…
2Cases cited22 opinions
- James v. United StatesSupreme Court of the United States · 1961
- Helvering v. San Joaquin Fruit & Investment Co.Supreme Court of the United States · 1936
- Norman A. Landry v. Hemphill, Noyes & Co., Norman A. Landry v. Hemphill, Noyes & Co.Court of Appeals for the First Circuit · 1973
- Alfred N. Hoffman and Deli Hoffman v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. Reba Martin, Inc.Court of Appeals for the Fifth Circuit · 1968
- Gordon v. duPont Glore Forgan Inc.Court of Appeals for the Fifth Circuit · 1973
17 more not listed; retrieve them via the Exa API.