TAXATION - FEDERAL INCOME TAX - INTANGIBLE SATISFACTION FROM GIFT AS INCOME TO THE DONOR

Authors

Walter B. Connolly, University of Michigan Law School

Abstract

Respondent, the owner of negotiable bonds, detached from them negotiable interest coupons shortly before their due date and delivered them as a gift to his son, who in the same year collected them at maturity. The commissioner of internal revenue ruled that the interest payments were taxable to the respondent donor. The circuit court of appeals reversed the order of the board of tax appeals sustaining the tax. Held, the commissioner was correct in including such interest payments in the taxable income of the donor. Helvering v. Horst, (U.S. 1940) 61 S. Ct. 144.

Recommended Citation

Walter B. Connolly, TAXATION - FEDERAL INCOME TAX - INTANGIBLE SATISFACTION FROM GIFT AS INCOME TO THE DONOR, 39 Mich. L. Rev. 495 (1941).
Available at: https://repository.law.umich.edu/mlr/vol39/iss3/21