Tilton v. Commissioner
United States Tax Court
On Apr. 4, 1978, Woodrow and Vella Tilton, petitioners' parents, transferred real property to petitioners personally and to Circle Bar Ranch, Inc., a corporation owned by petitioners.
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On Apr. 4, 1978, Woodrow and Vella Tilton, petitioners' parents, transferred real property to petitioners personally and to Circle Bar Ranch, Inc., a corporation owned by petitioners. Circle Bar filed for bankruptcy on June 23, 1981. In a proceeding to determine the corporation's tax liability, the bankruptcy court held Circle Bar liable as transferee for unpaid 1973 income taxes of Woodrow and Vella and allowed a secured claim for their unpaid gift taxes for the period ended June 30, 1978, attributable to the Apr. 4, 1978, transfers. Held, petitioners are liable as donee-transferees for the…
1Opinion of the Court
FEATHERSTON, Judge:
Respondent determined that petitioners are liable, as transferees and donees of the assets of their parents, Woodrow W. and Vella V. Tilton,1 for Federal gift tax and additions to tax under sections 6651(a)(1)2 and 6653(a) as follows:
Docket No. 12017-82: Daniel V. Tilton
Gift tax _Addition_ Taxable
deficiency Sec. 6651(a)(1) Sec. 6653(a) period ended
$331,685 $82,921.25 $16,584.25 6/30/78
Docket No. 12022-82: David V. Tilton
Taxable Gift tax Addition
period ended deficiency Sec. 6651(a)(1) Sec. 6653(a)
6/30/78 $331,685 $82,921.25 $16,584.25
The issues for decision are:(1) Whether…
2Cases cited25 opinions
- Montana v. United StatesSupreme Court of the United States · 1979
- Commissioner v. SternSupreme Court of the United States · 1958
- Commissioner v. WemyssSupreme Court of the United States · 1945
- Mysse v. CommissionerUnited States Tax Court · 1972
- Helvering v. HutchingsSupreme Court of the United States · 1941
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3Cited by16 opinions
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