Preston v. Commissioner
United States Board of Tax Appeals
On October 18, 1934, petitioner borrowed $125,000 from trust company A and delivered that amount to trust company B, as trustee, to be held under a trust indenture for the benefit of a sister-in-law. The trustee was authorized under the trust indenture to lend that entire amount to petitioner on his bond.
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On October 18, 1934, petitioner borrowed $125,000 from trust company A and delivered that amount to trust company B, as trustee, to be held under a trust indenture for the benefit of a sister-in-law. The trustee was authorized under the trust indenture to lend that entire amount to petitioner on his bond. On October 19, 1934, petitioner delivered to the trustee his bond under seal, in which he covenanted to pay $125,000 in 20 years with interest at 4 percent per annum; the trustee delivered $125,000 to petitioner, and petitioner used that amount to satisfy his loan from trust company A. Under…
1Opinion of the Court
WILLIAM P. T. PRESTON, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Preston v. Commissioner
Docket No. 101762.
United States Board of Tax Appeals
44 B.T.A. 973; 1941 BTA LEXIS 1250;
July 10, 1941, Promulgated
On October 18, 1934, petitioner borrowed $125,000 from trust company A and delivered that amount to trust company B, as trustee, to be held under a trust indenture for the benefit of a sister-in-law. The trustee was authorized under the trust indenture to lend that entire amount to petitioner on his bond. On October 19, 1934, petitioner delivered to the trustee his bond under…
2Cases cited8 opinions
- Cochran v. TaylorNew York Court of Appeals · 1937
- Gilman v. CommissionerUnited States Board of Tax Appeals · 1930
- Harris v. . ShorallNew York Court of Appeals · 1921
- Alexander v. Equitable Life Assurance SocietyNew York Court of Appeals · 1922
- Park v. CommissionerUnited States Board of Tax Appeals · 1938
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