T.C. Memo. 2007-61 UNITED STATES TAX COURT ESTATE OF FRANCES ELAINE FREEDMAN, DECEASED, ROBIN ELAINE CARNETTE, PERSONAL REPRESENTATIVE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 6416-04. Filed March 19, 2007. In late 1999, D received stock in ECNC in exchange for her interest in a business venture. In January of 2000, D contributed the stock to a recently opened joint brokerage account titled in her name and that of her son. Shares of ECNC were thereafter sold between late January and early March of 2000, generating substantial capital gains. Held: D, and not her son, is considered under State law to be the owner of all ECNC stock in the joint account and is therefore taxable on the full amount of the gain arising from its sale. Joe M. Gonzalez, for petitioner. Michael A. Pesavento, for respondent.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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