Facts
Pursuant to a separation agreement, the taxpayer's (ex-)wife agreed to relinquish any potential claims or marital rights, in exchange for which he transferred to her 1,000 shares of stock in DuPont. These shares had cost him $74,775.37, and had appreciated to $82,250 at the time of the transfer.
The government argued that the appreciation should be included in the taxpayer's gross income, viewing the transfer of property as an exchange for the release of an independent legal obligation. The taxpayer argued that the appreciation should not count as gross income, since the transfer was more like a division of property between co-owners than a sale that resulted in gain.
Read more about this topic: United States V. Davis
Famous quotes containing the word facts:
“Now, what I want is, Facts. Teach these boys and girls nothing but Facts. Facts alone are wanted in life. Plant nothing else, and root out everything else. You can only form the minds of reasoning animals upon Facts: nothing else will ever be of any service to them. This is the principle on which I bring up my own children, and this is the principle on which I bring up these children. Stick to Facts, sir!”
—Charles Dickens (1812–1870)
““It is of the highest importance in the art of detection to be able to recognise out of a number of facts which are incidental and which are vital.... I would call your attention to the curious incident of the dog in the night-time.”
“The dog did nothing in the night-time.”
“That was the curious incident.””
—Sir Arthur Conan Doyle (1859–1930)
“Now, what I want is, Facts. Teach these boys and girls nothing but Facts. Facts alone are wanted in life. Plant nothing else, and root out everything else. You can only form the minds of reasoning animals upon Facts: nothing else will ever be of any service to them. This is the principle on which I bring up my own children, and this is the principle on which I bring up these children. Stick to Facts, sir!”
—Charles Dickens (1812–1870)