Legal Opinion

Miller v. Commissioner

United States Board of Tax Appeals

Decided November 29, 1933No. Docket No. 58712;Published

The question of whether shares in a British corporation were held jointly or in common is decided under the laws of New York, the place where the assignment was made and the parties resided. Since there was no express declaration in the instrument that the shares were to be held jointly, they were held in common under the laws of New York.

1Opinion of the Court

CHARLES G. MILLER AND HAROLD B. MILLER, AS EXECUTORS OF THE ESTATE OF CHARLES A. MILLER, DECEASED, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Miller v. Commissioner

Docket No. 58712;

United States Board of Tax Appeals

29 B.T.A. 470; 1933 BTA LEXIS 935;

November 29, 1933, Promulgated

The question of whether shares in a British corporation were held jointly or in common is decided under the laws of New York, the place where the assignment was made and the parties resided. Since there was no express declaration in the instrument that the shares were to be held jointly, they were held…

2Cases cited1 opinion

  1. Miller v. CommissionerUnited States Board of Tax Appeals · 1933

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API