Florence G. Willock v. Commissioner
United States Tax Court
Petitioner acquired common stock by gift and by purchase. In 1929, the corporation split its common stock; new certificates were received by petitioner for the original certificates; and the shares held increased from the original amount of 1,907 shares to 4,767 shares. In 1930, petitioner transferred the 4,767 shares to a trustee in trust. Thereafter new certificates for 4,767 shares were issued in the name of the trustee. The trust was revocable.
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Petitioner acquired common stock by gift and by purchase. In 1929, the corporation split its common stock; new certificates were received by petitioner for the original certificates; and the shares held increased from the original amount of 1,907 shares to 4,767 shares. In 1930, petitioner transferred the 4,767 shares to a trustee in trust. Thereafter new certificates for 4,767 shares were issued in the name of the trustee. The trust was revocable. The trustee maintained records of certificate numbers, number of shares, dates of acquisition and cost. In 1941, upon receipt of advice from…
1Opinion of the Court
Florence G. Willock v. Commissioner.
Florence G. Willock v. Commissioner
Docket No. 8943.
United States Tax Court
1947 Tax Ct. Memo LEXIS 220; 6 T.C.M. (CCH) 487; T.C.M. (RIA) 47120;
May 2, 1947
Petitioner acquired common stock by gift and by purchase. In 1929, the corporation split its common stock; new certificates were received by petitioner for the original certificates; and the shares held increased from the original amount of 1,907 shares to 4,767 shares. In 1930, petitioner transferred the 4,767 shares to a trustee in trust. Thereafter new certificates for 4,767 shares were issued in the…
2Cases cited2 opinions
- Helvering v. RankinSupreme Court of the United States · 1935
- Ford v. CommissionerUnited States Board of Tax Appeals · 1936