Nieto v. Registrar of Property of San Germán

91 P.R. 658
CourtSupreme Court of Puerto Rico
DecidedJanuary 25, 1965
DocketNo. G-64-5
StatusPublished

This text of 91 P.R. 658 (Nieto v. Registrar of Property of San Germán) is published on Counsel Stack Legal Research, covering Supreme Court of Puerto Rico primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Nieto v. Registrar of Property of San Germán, 91 P.R. 658 (prsupreme 1965).

Opinion

Mr. Justice Blanco Lugo

delivered the opinion of the Court.

Section 1 of Act No. 303 of April 12, 1946, 13 L.P.R.A. § 881, provides, inter alia, that “When a property is transferred for less than its fair value, either nr money or money’s worth, or by exchange, the excess of the fair value of said property over the consideration in money or money’s worth, or thing for which said property was exchanged, shall be considered a gift, and shall be included in computing the total gifts made during the year.” The application of this provision has given rise to this administrative appeal.

The deed presented to be recorded — number 18, executed on February 3, 1964 before Notary Luis López de Victoria —and the entries in the registry show the following antecedents: that on April 9, 1963 José Antonio Colón and his wife Gloria purchased a certain property for the price of $4,000 — a 249.23 square-meter lot with a-zinc-roofed frame structure — located on Pedro Vargas Rodriguez Street in Guánica; that scarcely ten months later the Colons sold said property for the amount of $3,500 to Julio César Nieto and his wife Doris Vargas, who, being residents of New York city, were represented at the execution of the deed of sale by an agent with verbal authority. The note of refusal states that the $500 difference could constitute a gift and that inasmuch as the payment or the exemption of the corresponding tax has not been established, record is denied and a cautionary notice is entered.

In Cupeles v. Registrar, 87 P.R.R. 734 (1963), we expressly did not pass on the question of whether the sale of real property for less than the value for which it was acquired constitutes a taxable gift. It involved the sale of [660]*660a rural farm for the price of $6,000 which had been purchased seven years before for the amount of $8,500. Since it appeared from the deed that some crops which were included in the original transaction were not mentioned in the latter, we considered that the facts did not justify our passing on the ground adduced by the registrar to deny record, which was identical with the one mentioned in the note appealed from. The situation now under consideration is different.

In Freeman v. Noguera, Sec. of the Treas., 82 P.R.R. 298, 301-304 (1961), we gave the history of the legislation passed since 1901 concerning the assessment of the so-called inheritance tax. Since then, and until the enactment of Act No. 303 of April 12, 1946, supra, the only taxable event was death. Although donations were mentioned, see § 1 of Act No. 99 of August 29, 1925 (Sess. Laws, p. 790) and § 368 of the Political Code of 1902 (Revised Statutes 1902, p. 455), this reference was limited to those which contemplated the granting of possession, the nude ownership, or usufruct, after the death of the grantor, and only covered donations inter vivos when it was intended to distribute the property in life.1 Except in this case and in those subject to collation, § 989 in reference to 990 of the Civil Code, 1930 ed., 31 L.P.R.A. §§ 2841 and 2842,2 the donation inter vivos was not subject to the payment of such tax.

Act No. 303 substantially altered the system enlarging the ambit of assessment in such a manner that it practically covers every kind of transfer, whether inter vivos [661]*661or mortis causa, and among them the modality we shall call transfer for less than its fair value. This provision is a literal translation of § 2512(b) of the Federal Code in force, 26 U.S.C. § 2512(b),3 which copied literally in its English version reads as follows: “Where property is transferred for less than an adequate and full consideration in money or money’s worth, then the amount by which the value of the property exceeded the value of the consideration shall be deemed a gift, and shall be included in computing the amounts of gifts made during the calendar year.” The only addition to the local provision is the inclusion of an express reference to the value of property received in exchange. This precept, which in the federal law appears in the sections on valuation was incorporated in Puerto Rico as part of the definitions of taxable event “gift.” In Commissioner v. Wemyss, 324 U.S. 303, 306 (1945), it was stated that “had Congress taxed ‘gifts’ simpliciter, it would be appropriate to assume that the term was used in its colloquial sense, and a search for ‘donative intent’ would be indicated. But Congress intended to use the term ‘gifts’ in its broadest and most comprehensive sense. (Citations.)” Hence, as it immediately follows in the above citation, it is not necessary to resort to but rather dispense with notions of common law considerations for the purposes of the gift tax. We have attributed the same intention to our legislator and, as a result, it is not indispensable to resort to civil law to formulate the concept of gift. Consolidated Cigar Corp. v. Registrar, 83 P.R.R. 723, 726 (1961).

Now, concerning transfers for less than their fair value it does not mean that respective considerations have [662]*662to be evenly balanced, even when a literal construction of the statute might lead to that result. It was so held initially by the Tax Court of the United States, William H. Gross, 7 T.C. 837, 846-847 (1946); Herbert Jones, 1 T.C. 1207 (1943). A similar view was taken by the Commissioner of Internal Revenue upon promulgating regulations, 26 C.F.R. § 25.2512-8 (1954), and its forerunners, all drafted in similar terms. Mertens4 comments that “a long history of administrative construction holds, in effect, that no examination need be made as to the fullness and adequacy of the consideration where the transfer is made in connection with a transaction in the ordinary course of business. The basis for such exclusion is a presumption that such a transaction involves adequate and full consideration in money or money’s worth.” All that is required is that the transaction be legitimate, the outcome of ordinary business transactions and free from any donative intent. The same view is held by Lowndes and Kramer, Federal Estate and Gift Taxes 310-313 (Prentice Hall, 1956), and Beveridge, Law of Federal Gift Taxation 46-49, § 3.03 (Callaghan and Company, 1958). The- Federal Code defines the standard with the graphic phrase: “a transaction which is bona fide, at arm’s length, and free from any donative intent.” This, of course, excludes transactions in which the consideration of one' of the obligations or promises is merely nominal or unsubstantial, Minnie E. Deal, 29 T.C. 730 (1958), or in which the dona-tive intent is predominant, cf. Descartes, Treas. v. Tax Court, 70 P.R.R. 537 (1949).

Mertens, op. cit. at 98, § 34.19, points out that the inquiry should be confined to determining whether the transaction is a genuine business transaction, even though this is not directly related to the business of the taxpayer. It seems .perti[663]*663nent to cite here from the Tax Court in Estate of Monroe D. Anderson, 8 T.C.

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Related

Commissioner v. Wemyss
324 U.S. 303 (Supreme Court, 1945)
Rosenthal v. Commissioner of Internal Revenue
205 F.2d 505 (Second Circuit, 1953)
Jones v. Commissioner
1 T.C. 1207 (U.S. Tax Court, 1943)
Deal v. Commissioner
29 T.C. 730 (U.S. Tax Court, 1958)
Weller v. Commissioner
38 T.C. 790 (U.S. Tax Court, 1962)
Estate of Anderson v. Commissioner
8 T.C. 706 (U.S. Tax Court, 1947)

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91 P.R. 658, Counsel Stack Legal Research, https://law.counselstack.com/opinion/nieto-v-registrar-of-property-of-san-german-prsupreme-1965.