Haygood v. Commissioner
United States Tax Court
Petitioner deeded properties to each of her two sons and in return took a vendor's lien note from each for the full value of the properties payable $ 3,000 per year, the first payments being due the day after the deeds were executed. Each vendor's lien note was secured by a deed of trust on the properties transferred.
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Petitioner deeded properties to each of her two sons and in return took a vendor's lien note from each for the full value of the properties payable $ 3,000 per year, the first payments being due the day after the deeds were executed. Each vendor's lien note was secured by a deed of trust on the properties transferred. In accordance with her intention when she transferred the properties, petitioner canceled the $ 3,000 payments due the day after the execution of the deeds and in subsequent years canceled the other $ 3,000 payments. Held, petitioner made gifts of the transferred properties to…
1Opinion of the Court
Selsor R. Haygood, Petitioner, v. Commissioner of Internal Revenue, Respondent
Haygood v. Commissioner
Docket No. 3240-63
United States Tax Court
42 T.C. 936; 1964 U.S. Tax Ct. LEXIS 56;
August 24, 1964, Filed
Decision will be entered for petitioner.
Petitioner deeded properties to each of her two sons and in return took a vendor's lien note from each for the full value of the properties payable $ 3,000 per year, the first payments being due the day after the deeds were executed. Each vendor's lien note was secured by a deed of trust on the properties transferred. In accordance with her intention…
2Cases cited14 opinions
- Commissioner v. WemyssSupreme Court of the United States · 1945
- Smith v. ShaughnessySupreme Court of the United States · 1943
- Robinette v. HelveringSupreme Court of the United States · 1943
- United States v. H. A. Phillips, Trustee for C. J. Dick Towing Company, BankruptCourt of Appeals for the Fifth Circuit · 1959
- Bergan v. CommissionerUnited States Tax Court · 1943
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