Thompson v. Commissioner
United States Board of Tax Appeals
A voluntary contribution by a taxpayer to a corporation of which he and his family were sole shareholders, held a gift subject to gift tax, and, since the corporation and not each shareholder was the donee, there is only one $5,000 exclusion.
1Opinion of the Court
*122OPINION.
SteRnhagen:
In determining the deficiency, the Commissioner ruled that the amounts contributed by the petitioner to the corporation in the years 1933, 1934, and 1935 were gifts, taxable in the aggregate as such, and that there was but one exclusion of $5,000 for each year. The petitioner assails this determination, primarily contending that the transfers to the corporation were not gifts but were contributions of paid-in surplus; and, in the alternative, if they are to be characterized as gifts, such characterization can only be applied to the interest which by his contribution the…
2Cases cited2 opinions
- Dalton v. BowersSupreme Court of the United States · 1932
- Hellmich v. HellmanSupreme Court of the United States · 1928
3Cited by10 opinions
- CTUW Hollingsworth v. CommissionerUnited States Tax Court · 1986
- Stephen F. Heringer, Mabel H. Heringer, John F. Heringer, and Alta G. Heringer v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1956
- Gregory v. State of CaliforniaCalifornia Court of Appeal · 1946
- CTUW Hollingsworth v. CommissionerUnited States Tax Court · 1986
- Gregory v. State of CaliforniaCalifornia Court of Appeal · 1946
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