Legal Opinion

Hindes v. Commissioner

United States Board of Tax Appeals

Decided December 6, 1933No. Docket Nos. 61230, 61251-61253, 61282-61285, 61308-61311Published

A established trusts for benefit of his relatives and, as trust property, transferred common stock to trustees upon gifts certain. Thereafter, upon A's request but without consideration. the beneficiaries authorized the trustees and donor to make any changes in the trusts which they desired.

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A established trusts for benefit of his relatives and, as trust property, transferred common stock to trustees upon gifts certain. Thereafter, upon A's request but without consideration. the beneficiaries authorized the trustees and donor to make any changes in the trusts which they desired. The trustees transferred the common stock to the donor, who thereupon executed new declarations of trust, some of which were upon substantially different terms and transferred certain preferred stock to the trustees for trust property. Held, the transactions were not taxable exchanges of stock.

1Opinion of the Court

JOSEPH F. HINDES, TRUSTEE FOR ANNA E. POPE, TRUSTEE FOR JOHN W. EMERSON, PETITIONER, ET AL., 1v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Hindes v. Commissioner

Docket Nos. 61230, 61251-61253, 61282-61285, 61308-61311.

United States Board of Tax Appeals

29 B.T.A. 498; 1933 BTA LEXIS 929;

December 6, 1933, Promulgated

A established trusts for benefit of his relatives and, as trust property, transferred common stock to trustees upon gifts certain. Thereafter, upon A's request but without consideration. the beneficiaries authorized the trustees and donor to make any changes in the trusts which…

2Cases cited1 opinion

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

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