Carson Estate Co. v. Commissioner
United States Board of Tax Appeals
Where a corporation issued to petitioner certificates of ownership purporting to evidence a sale of the corporation's title and interest, to a specified extent, in municipal bonds, the interest on which was exempt from income tax, deposited with a trustee under a trust agreement, which instruments, construed as a whole, indicated a transfer of beneficial ownership in the bonds was intended and effected, and not a loan, held, that petitioner became the beneficial owner of…
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Where a corporation issued to petitioner certificates of ownership purporting to evidence a sale of the corporation's title and interest, to a specified extent, in municipal bonds, the interest on which was exempt from income tax, deposited with a trustee under a trust agreement, which instruments, construed as a whole, indicated a transfer of beneficial ownership in the bonds was intended and effected, and not a loan, held, that petitioner became the beneficial owner of such bonds, and the interest it received, through the trustee, was in payment of interest on those bonds and therefore…
1Opinion of the Court
OPINION.
Leech:
These consolidated proceedings seek redetermination of income tax deficiencies in the amounts of $2,086,02 for the year 1926, $1,780.08 for the year 1927, and $1,815.31 for the year 1928. The total deficiencies for 1926 and 1927 are not in controversy.
The facts are stipulated. A rather full resume of them follows:
Petitioner is a California corporation It acquired certain certificates of ownership from Municipal Bond Co., hereinafter referred to as the corporation.
The form of ownership certificate issued by the corporation provides that the corporation “ does hereby sell and…
2Cases cited9 opinions
- Goodyear Dental Vulcanite Co. v. DavisSupreme Court of the United States · 1880
- Chase & Baker Co. v. National Trust & Credit Co.District Court, N.D. Illinois · 1914
- Cary v. SleadIllinois Supreme Court · 1906
- Lyons v. SniderSupreme Court of Minnesota · 1917
- Paulson v. WeeksOregon Supreme Court · 1916
4 more not listed; retrieve them via the Exa API.
3Cited by4 opinions
- Carson Estate Co. v. CommissionerUnited States Board of Tax Appeals · 1934
- Goulder v. CommissionerUnited States Board of Tax Appeals · 1939
- Schoellkopf v. CommissionerUnited States Board of Tax Appeals · 1935
- Woolley v. CommissionerUnited States Board of Tax Appeals · 1939