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Estate of Anderson v. Commissioner
United States Tax Court
8 T.C. 706 (1947)
Monroe Anderson and W. L. Clayton were senior executives in the Anderson-Clayton business, which dealt in cotton. Anderson-Clayton’s common stock was not actively traded but instead was principally held by executives in the company. The business used the common stock as part of its profit-sharing model. Under the model, as a senior executive shifted responsibility from himself to a more junior employee, the senior executive would sell some of his shares to the junior employee for less than the shares’ true value. The Internal Revenue Service (defendant) determined that the fact that the sales occurred at a discount made the transfers subject to gift tax and assessed tax deficiencies against Clayton and Anderson’s estate (plaintiffs). Clayton and Anderson’s estate challenged this determination in tax court.
Rule of Law
Holding and Reasoning (Arundell, J.)
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