Gerald A. and Henrietta V. Rauenhorst v. CIR

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Full Text of Court Cases
October 7, 2002
estate and gift taxation

Gerald A. and Henrietta V. Rauenhorst v. CIR
119 T.C. No. 9 (2002)
US
Federal Court
United States Tax Court
Ruwe

Summary

The full Tax Court declined to permit the IRS to disavow Rev. Rul. 78-197, upon which the taxpayers relied, and, thereby, used the anticipatory assignment of income doctrine to recharacterize the transfer of warrants in a soon to be acquired corporation t ...
Gerald A. and Henrietta V. Rauenhorst v. CIR
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See Also

IRS Cannot Disavow Revenue Ruling 78-197 to Recharacterize Charitable Donation

The full Tax Court con­sidered whether the anticipatory assignment of in­come doctrine should be applied to recharacterize the transfer of warrants to four charitable organiza­tions.