Snyder v. Commissioner
United States Tax Court
Petitioner Irving Snyder owned certain real property. In 1957 he deeded the property to two creditors as collateral for his indebtedness. In 1967 the creditors deeded the property to Snyder's sister, petitioner Rose Baird, who simultaneously issued a mortgage on the property to secure a bank loan which was used to repay Snyder's creditors. Later in 1967 a portion of the property was sold, and the bank's mortgage was paid off.
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Petitioner Irving Snyder owned certain real property. In 1957 he deeded the property to two creditors as collateral for his indebtedness. In 1967 the creditors deeded the property to Snyder's sister, petitioner Rose Baird, who simultaneously issued a mortgage on the property to secure a bank loan which was used to repay Snyder's creditors. Later in 1967 a portion of the property was sold, and the bank's mortgage was paid off. In 1968 the balance of the property was sold, the purchaser issuing a purchase-money installment note to Rose Baird. In 1970 Rose Baird assigned the installment note to…
1Opinion of the Court
Fay, Judge:
Respondent determined deficiencies in income tax and gift tax, and penalties with respect thereto, against petitioners Rose Baird and Irving Snyder (as transferee of Rose Baird) for the taxable year 1970, as follows:
Amount Additions to tax Docket No. Petitioner income tax Sec. 6651(a)(1)2 Sec. 6651(a)(2)
8827-73 Rose Baird_ $19,073.44
8824-73 Irving Snyder, transferee_ 19,073.44 — —
Additions to tax Docket No. Petitioner Amount Sec. 6651(a)(1) Sec. 6651(a)(2) Gift tax
8826-73 Rose Baird_ 31,776.48 $7,149.71 $4,766.47
8825-73 Irving Snyder, donee, transferee_ 31,776.48 7,149.71 4,766.47
Th…
2Cases cited8 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Higgins v. SmithSupreme Court of the United States · 1940
- Commissioner v. P. G. Lake, Inc.Supreme Court of the United States · 1958
- Griffiths v. CommissionerSupreme Court of the United States · 1939
3 more not listed; retrieve them via the Exa API.
3Cited by27 opinions
- Estate of Young v. CommissionerUnited States Tax Court · 1983
- Hang v. CommissionerUnited States Tax Court · 1990
- Weigl v. CommissionerUnited States Tax Court · 1985
- Irving Snyder, Transferee, Rose Baird, Transferor v. United StatesCourt of Appeals for the Tenth Circuit · 1980
- Computervision Int'l Corp. v. CommissionerUnited States Tax Court · 1996
22 more not listed; retrieve them via the Exa API.