Stern v. Commissioner
United States Tax Court
1. Income -- Realization -- Gift Before. -- Former owner of shares held not taxable on gain from liquidation where he made a valid and complete gift of the shares prior to the liquidation. 2. Family Partnership -- Trusts Included. -- The definition of a partnership in section 3797 includes a partnership in which trusts were limited partners and the distributive shares of the trusts are not taxable to the grantor, the general partner, where the trusts contributed valuable…
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1. Income -- Realization -- Gift Before. -- Former owner of shares held not taxable on gain from liquidation where he made a valid and complete gift of the shares prior to the liquidation. 2. Family Partnership -- Trusts Included. -- The definition of a partnership in section 3797 includes a partnership in which trusts were limited partners and the distributive shares of the trusts are not taxable to the grantor, the general partner, where the trusts contributed valuable property which was an income producing factor.
1Opinion of the Court
Theodore D. Stern, Petitioner, v. Commissioner of Internal Revenue, Respondent
Stern v. Commissioner
Docket No. 19703
United States Tax Court
15 T.C. 521; 1950 U.S. Tax Ct. LEXIS 61;
October 18, 1950, Promulgated
Decision will be entered under Rule 50.
1. Income -- Realization -- Gift Before. -- Former owner of shares held not taxable on gain from liquidation where he made a valid and complete gift of the shares prior to the liquidation.
2. Family Partnership -- Trusts Included. -- The definition of a partnership in section 3797 includes a partnership in which trusts were limited partners and the…
2Cases cited6 opinions
- Stern v. CommissionerUnited States Tax Court · 1950
- Cook v. CommissionerUnited States Tax Court · 1945
- Blumberg v. CommissionerUnited States Tax Court · 1948
- Theurkauf v. CommissionerUnited States Tax Court · 1949
- Fickert v. CommissionerUnited States Tax Court · 1950
1 more not listed; retrieve them via the Exa API.