Walter R. Carrington and Ada Raye Carrington v. Commissioner of Internal Revenue

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• holding, in an income tax case, that where respondent seeks to use the step transaction doctrine to disregard a donation of appreciated property to a charitable organization, the central inquiry is whether the donor parted with all dominion and control
• holding, in an income tax case, that where respondent seeks to use the step transaction doctrine to disregard a donation of appreciated property to a charitable organization, the central inquiry is whether the donor parted with all dominion and control
• holding, in an income tax case, that where respondent seeks to use the step transaction doctrine to disregard a donation of appreciated property to a charitable organization, the central inquiry is whether the donor parted with all dominion and control
• respecting form of transaction where donee redeemed stock eight days after it was donated
• respecting form of transaction where donee redeemed stock eight days after it was donated
• “A gift of stock between competent parties requires donative intent, actual delivery, and relinquishment of dominion and control by the donor.”

Source: CourtListener parenthetical corpus (CC0).