Dunham v. Commissioner
United States Tax Court
Held, that under the arrangements involved herein the petitioner was not liable for tax on the dividends received by her during the taxable years 1954, 1955, and 1956 from corporate stock standing in the name of her daughter during those years.
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Held, that under the arrangements involved herein the petitioner was not liable for tax on the dividends received by her during the taxable years 1954, 1955, and 1956 from corporate stock standing in the name of her daughter during those years. Held, further, that petitioner was not liable for tax on the dividends received by her during the period January 1 to July 28, 1954, from stock standing in the name of her son during that period but was liable for corporate tax on the dividends received by her during the remainder of 1954 and the taxable years 1955 and 1956 when the stock which…
1Opinion of the Court
Withey, Judge:
The respondent has determined deficiencies in the income tax of the petitioner for the years 1954, 1955, and 1956 in the respective amounts of $18,394.08, $15,850.52, and $26,845.40. The sole issue is whether dividends paid to petitioner in accordance with an assignment thereof by her son and daughter are income to her and taxable as such.
FINDINGS OF FACT.
The stipulated facts are found as fact.
Petitioner resides at Scranton, Pennsylvania, and filed her individual income tax returns for the years here involved with the district director of internal revenue at that city.
Petitioner…
2Cases cited8 opinions
- Helvering v. CliffordSupreme Court of the United States · 1940
- Lucas v. EarlSupreme Court of the United States · 1930
- Helvering v. HorstSupreme Court of the United States · 1940
- Blair v. CommissionerSupreme Court of the United States · 1937
- Harrison v. SchaffnerSupreme Court of the United States · 1941
3 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Dunham v. CommissionerUnited States Tax Court · 1961