(Download) "National Labor Relations Board v. Tri-State Casualty Insurance Co." by Tenth Circuit. United States Court of Appeals # eBook PDF Kindle ePub Free
eBook details
- Title: National Labor Relations Board v. Tri-State Casualty Insurance Co.
- Author : Tenth Circuit. United States Court of Appeals
- Release Date : January 21, 1951
- Genre: Law,Books,Professional & Technical,
- Pages : * pages
- Size : 74 KB
Description
This proceeding is here on petition to review a decision of the Tax Court relating to the liability of Lewis B. Maytag, hereinafter referred to as the taxpayer, for gift tax for the calendar year 1944. On March 8, 1944, the taxpayer created four trusts, one for the benefit of each of his four children. On that day he transferred to each trust 25,000 shares of the common stock of The Maytag Company; and on March 16, 1944, he transferred to each trust 10,000 shares of cumulative preference stock of the company. All of the transfers were made as gifts. In his gift tax return, the taxpayer reported the four gifts totalling 100,000 shares of common stock at a total value of $390,000, and the four gifts totalling 40,000 shares of preference stock at a total value of $1,048,000. The Commissioner of Internal Revenue determined that the value of each of the four gifts of 25,000 shares of common stock was $121,875, or a total of $487,500; and that the value of each of the four gifts of 10,000 shares of preference stock was $335,000, or a total of $1,340,000. A resulting deficiency in gift tax was imposed. In the statement which accompanied the letter advising the taxpayer that the deficiency had been determined, the Commissioner explained that the shares were included at a value equal to the means of the high and low sales prices on the New York Stock Exchange on the dates of the respective gifts. The Tax Court sustained the deficiency in tax, and the taxpayer appealed.