Estate of Frances Elaine Freedman v. Comm'r
United States Tax Court
In late 1999, D received stock in ECNC in exchange for her interest in a business venture. In January of 2000, D contributed the stock to a recently opened joint brokerage account titled in her name and that of her son. Shares of ECNC were thereafter sold between late January and early March of 2000, generating substantial capital gains.
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In late 1999, D received stock in ECNC in exchange for her interest in a business venture. In January of 2000, D contributed the stock to a recently opened joint brokerage account titled in her name and that of her son. Shares of ECNC were thereafter sold between late January and early March of 2000, generating substantial capital gains. Held: D, and not her son, is considered under State law to be the owner of all ECNC stock in the joint account and is therefore taxable on the full amount of the gain arising from its sale.
1Opinion of the Court
ESTATE OF FRANCES ELAINE FREEDMAN, DECEASED, ROBIN ELAINE CARNETTE, PERSONAL REPRESENTATIVE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Estate of Frances Elaine Freedman v. Comm'r
No. 6416-04
United States Tax Court
T.C. Memo 2007-61; 2007 Tax Ct. Memo LEXIS 61; 93 T.C.M. (CCH) 1007;
March 19, 2007, Filed
In late 1999, D received stock in ECNC in exchange for her interest in a business venture. In January of 2000, D contributed the stock to a recently opened joint brokerage account titled in her name and that of her son. Shares of ECNC were thereafter sold between late January and…
2Cases cited23 opinions
- Zenith Radio Corp. v. Hazeltine Research, Inc.Supreme Court of the United States · 1971
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- Commissioner v. Glenshaw Glass Co.Supreme Court of the United States · 1955
- Morgan v. CommissionerSupreme Court of the United States · 1940
- In the Interest of G. M.Texas Supreme Court · 1980
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