Kelly v. Commissioner

31 T.C. 493, 1958 U.S. Tax Ct. LEXIS 22
CourtUnited States Tax Court
DecidedDecember 10, 1958
DocketDocket Nos. 60753, 60754, 60755
StatusPublished
Cited by1 cases

This text of 31 T.C. 493 (Kelly v. Commissioner) is published on Counsel Stack Legal Research, covering United States Tax Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Kelly v. Commissioner, 31 T.C. 493, 1958 U.S. Tax Ct. LEXIS 22 (tax 1958).

Opinion

OPINION.

Raum, Judge:

1. Did the decedent and his wife make valid gifts of their community property on April 28,1950 ? The petitioners contend that any gifts made were not valid because (a) decedent was incompetent at the time of the alleged gifts; (b) he gave away all of his property, and, therefore, the gifts were void under Louisiana law; (c) the gifts were intended to take effect only on death and were invalid testamentary dispositions; and (d) the 1952 judgment adjudicated the gifts to be invalid and is controlling.

Article 1475 of the Louisiana Civil Code provides that “[t]o make a donation either inter vivos or mortis causa, one must be of sound mind.” The burden of proving that the decedent was not of sound mind at the time he executed the acts of donation on April 28, 1950, was on the petitioners. They have not sustained this burden. The evidence submitted by them indicates that the decedent on April 28,1950, was seriously ill, emotionally upset, depressed by reason of the fact that he knew he had but a short time to live, and that he was receiving drugs for the alleviation of pain. It does not convince us, however, that he was not mentally competent and did not know what he was doing when he executed the acts of donation.

Article 1497 of the Civil Code of Louisiana provides that “[t]he donation inter vivos shall in no case divest the donor of all his property; he must reserve to himself enough for subsistence; if he does not do it, the donation is null for the whole.” Cf. Kirby v. Kirby, 176 La. 1037, 147 So. 71; Kelly v. Kelly, 131 La. 1024, 60 So. 671; Welch v. Forrest Lumber Co., 151 La. 960, 92 So. 400. The prohibition against making a donation orrmium bonorvm applies to a donation made by a man to his wife as well as to a donation made by him to a stranger. Succession of Suarez, 131 La. 500, 59 So. 916.

The decedent on April 28, 1950, made three gifts to his children. When these gifts were consummated, he still retained his community interest in his home, household furnishings and personal effects, his automobile,1 and cash in bank amounting to about $26,000. Decedent withdrew the cash in bank after April 28,1950, and placed it in United States bonds in the name of his wife. The bonds were issued in June 1950. It is not possible to determine from the evidence exactly when the cash was withdrawn from the bank. The only evidence relating to this withdrawal was given by the decedent’s son, Joe T. Kelly. He testified that he presumed the decedent signed the check for the withdrawal ; that he went to the bank and withdrew the money; and that he “would say” the withdrawal was made in May although he could not recollect exactly when it was made. He also testified, “I think the check for those bonds was written right at the time when all the rest of the instruments, in other words, he [the decedent] had a housecleaning there all at once.”

In support of their contention that the gifts were void because decedent did not retain enough for subsistence, the petitioners urge that the gifts to the three children of decedent and the “gift of the cash” to his wife were part of the same transaction; that all gifts were, so to speak, part of decedent’s plan of complete disposal of his property, known to and acquiesced in by the donees; and that there was, in substance, one gift. They argue that if a gift of all of one’s property is void, it would be illogical to hold that where such a gift is made in segments, the last donee must disgorge, but the donee who is first by a few days or a few minutes may retain the fruits of such forbidden act.

There is no convincing evidence that on April 28, 1950, when decedent made the gifts to his three children, he was contemplating any gift to his wife or then took any step to make such a gift.2 Joe T. Kelly’s testimony in this respect was vague and unsatisfactory. All that the evidence really shows is that at some undisclosed time after April 28, the decedent withdrew approximately $26,000 from his bank account and placed these funds in United States bonds in the name of his wife. Assuming that by these acts the decedent intended to make a gift to her, that gift appears to have been a gift of bonds and not a “gift of the cash.” Such a gift could not have been completed prior to the purchase of the bonds, which occurred after the consummation of the gifts to the children. In the light of the evidence produced we cannot find that the gifts to the children, and the gift, if any, to the wife, were part of the same transaction, and, in substance, one gift. The former did not leave the decedent without sufficient property for subsistence since he retained at least $26,000 in cash in addition to his home, personal effects, and automobile. Moreover, even if the assumed gift of the $26,000 in bonds be combined with the three gifts to the children, it is not clear that he so stripped himself of assets as to render the gifts void. The estate tax return shows community “cash on hand” in the amount of $1,650, and we cannot say on the record before us that the decedent failed to retain enough for his subsistence so as to bring article 1497 of the Louisiana Civil Code into play.

Petitioners contend further that the gifts made by the decedent on April 28, 1950, were not intended to take effect presently, but only on death, and were, at best, invalid donations mortis causa. Pertinent provisions of the Louisiana Civil Code are noted in the margin.3 We are unable to agree with petitioners. The acts of donation made by decedent on April 28, 1950, clearly evidence his intention to make present gifts to his children of the property described therein. They were passed and signed in the presence of two witnesses and a notary. They were accepted by the donees in precise terms, and were recorded. There is no expression in the acts indicating that the gifts were to take effect at or after the death of the decedent. Cf. Succession of Sinnott v. Hibernia Nat. Bank, 105 La. 705, 30 So. 233; Johnson v. Waters, 111 U. S. 640. We hold that the donations made by the decedent on April 28, 1950, were valid gifts inter vivos under the laws of Louisiana and were effective on that date, when the acts of donation were executed.

The petitioners also contend that the effect of the 1952 State court proceedings in the Fifth Judicial District Court was to adjudicate that there never was an effective 1950 gift under Louisiana law, and that this determination is binding on this Court. In the joint petition filed in the State court proceedings, the petitioners did not allege that the decedent attempted to make, or made, any gift to his wife prior to his death, but simply urged that decedent’s desire that she should have full and complete ownership of his home, household furnishings and personal effects, automobile, and United States bonds be recognized. With respect to the property included in the 1950 acts of donation, the petitioners alleged that the decedent on April 28, 1950, “purported and attempted to donate” certain property to each of his three children “in contemplation of death”; and that they desired that the -wishes of the decedent, as expressed in the acts of donation, be given full force and effect.

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Related

Kelly v. Commissioner
31 T.C. 493 (U.S. Tax Court, 1958)

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Bluebook (online)
31 T.C. 493, 1958 U.S. Tax Ct. LEXIS 22, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kelly-v-commissioner-tax-1958.