Robinson v. Commissioner

Board of Tax Appeals

Robinson v. Commissioner

4 B.T.A. 47, 1926 BTA LEXIS 2384

CourtUnited States Board of Tax Appeals

DecidedApril 22, 1926

DocketDocket No. 6341.

StatusPublished

This text of 4 B.T.A. 47 (Robinson v. Commissioner) is published on Counsel Stack Legal Research, covering United States Board of Tax Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook

Robinson v. Commissioner, 4 B.T.A. 47, 1926 BTA LEXIS 2384 (bta 1926).

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Opinion

FINDINGS OF FACT.

F. M. Robinson, the decedent, was a resident of Atlanta, Ga., during the year 1920. Sometime between January and July, 1919, he gave his wife a certain promissory note, bearing interest at the rate of 6 per cent per annum, executed by Asa G. Candler, Inc., in the amount of $204,800. This gift was made in the presence of a witness and was effected by endorsement and delivery of the note.

On December 31, 1919, Asa G. Candler, Inc., issued its check, payable to the order of F. M. Robinson, for interest on the note in question for the six-month period, from July 1, 1919, to December 31, 1919, in the amount of $6,144. Early in January, 1920, F. M. Robinson endorsed such check, and the proceeds were deposited either to his credit or to the credit of his wife, and its amount was included by Mrs. F. M. Robinson in her income for 1920, and tax paid thereon. Neither the decedent nor his wife kept any regular books of account. They made separate income-tax returns for the year in question on the cash receipts and disbursements basis. The amount of $6,144 was not income of the decedent.

Order of redetermination will be entered on 15 days' notice, under Bule 50.

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FINDINGS OF FACT.

F. M. Robinson, the decedent, was a resident of Atlanta, Ga., during the year 1920. Sometime between January and July, 1919, he gave his wife a certain promissory note, bearing interest at the rate of 6 per cent per annum, executed by Asa G. Candler, Inc., in the amount of $204,800. This gift was made in the presence of a witness and was effected by endorsement and delivery of the note.

On December 31, 1919, Asa G. Candler, Inc., issued its check, payable to the order of F. M. Robinson, for interest on the note in question for the six-month period, from July 1, 1919, to December 31, 1919, in the amount of $6,144. Early in January, 1920, F. M. Robinson endorsed such check, and the proceeds were deposited either to his credit or to the credit of his wife, and its amount was included by Mrs. F. M. Robinson in her income for 1920, and tax paid thereon. Neither the decedent nor his wife kept any regular books of account. They made separate income-tax returns for the year in question on the cash receipts and disbursements basis. The amount of $6,144 was not income of the decedent.

Order of redetermination will be entered on 15 days' notice, under Bule 50.

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Bluebook (online)

4 B.T.A. 47, 1926 BTA LEXIS 2384, Counsel Stack Legal Research, https://law.counselstack.com/opinion/robinson-v-commissioner-bta-1926.

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