Bell v. Commissioner
United States Tax Court
Petitioner purchased stock from her father in exchange for her promise to pay her father and his wife an annuity of $ 15,000 per year for as long as either of them lived. In exchange for the annuity, the father made an absolute assignment of the stock to petitioner.
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Petitioner purchased stock from her father in exchange for her promise to pay her father and his wife an annuity of $ 15,000 per year for as long as either of them lived. In exchange for the annuity, the father made an absolute assignment of the stock to petitioner. Although petitioner's obligation to make the promised annuity payments was not contingent upon sufficient dividend income from the purchased stock, she did not have sufficient income and assets to make the payments without those dividends. Held, petitioner's promise to pay an annuity did not constitute an indebtedness within the…
1Opinion of the Court
Rebecca Bell, Petitioner v. Commissioner of Internal Revenue, Respondent
Bell v. Commissioner
Docket No. 4789-79
United States Tax Court
76 T.C. 232; 1981 U.S. Tax Ct. LEXIS 172;
February 18, 1981, Filed
Decision will be entered for the respondent.
Petitioner purchased stock from her father in exchange for her promise to pay her father and his wife an annuity of $ 15,000 per year for as long as either of them lived. In exchange for the annuity, the father made an absolute assignment of the stock to petitioner. Although petitioner's obligation to make the promised annuity payments was not contingent…
2Cases cited15 opinions
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Autenreith v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1940
- Reliable Incubator & Brooder Co. v. CommissionerUnited States Tax Court · 1946
- Klein v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1936
- John C. W. Dix and Caroline W. Dix v. Commissioner of Internal Revenue, George E. Dix v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1968
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