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.
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