Legal Opinion

Lord v. Commissioner

United States Board of Tax Appeals

Decided April 18, 1934No. Docket No. 59385PublishedCited by 1 opinion

Petitioner's right to receive corporate stock was initiated while he was domiciled in the State of Oregon. His removal to the State of Washington before receipt of the stock did not change the character of it from separate to community property, and the income represented by the proceeds of the sale of the stock was taxable to petitioner as his separate income.

1Opinion of the Court

*426OPINION.

Arundell:

We have no question here as to whether or not the amount received by petitioner from Deere & Co. constituted income. The question presented is whether such income was the separate income of petitioner or community income divisible between petitioner and his wife, they being residents of the State of Washington at the time of receipt.

Petitioner’s view is that the contract of April 8, 1918, and all his rights under it, expired when he left the service of Deere & Co.; that there was no consideration on his part for the offer contained in the letter of November 20, 1924, hence it…

2Cases cited14 opinions

  1. Guye v. GuyeWashington Supreme Court · 1911
  2. Riddoch v. StateWashington Supreme Court · 1912
  3. Long v. Pierce CountyWashington Supreme Court · 1900
  4. Lawson v. RipleySupreme Court of Louisiana · 1841
  5. Brookman v. DurkeeWashington Supreme Court · 1907

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3Cited by1 opinion

  1. Lord v. CommissionerUnited States Board of Tax Appeals · 1934

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