# Heringer v. Commissioner > United States Tax Court · January 26, 1954 · 21 T.C. 607 URL: https://www.frixlaw.com/law-library/cases/4476625 ## Case - **Full name:** Stephen F. Heringer, 1 v. Commissioner of Internal Revenue - **Court:** United States Tax Court - **Decided:** January 26, 1954 - **Citations:** 21 T.C. 607; 1954 U.S. Tax Ct. LEXIS 308 - **Precedential status:** Published - **Opinion:** Opinion of the court by Opper - **Judges:** Fossan, Opper - **Cited by:** 0 later opinions in the Frix Law Library ## Citator (automated) - No negative treatment found by the automated citator. That is not the same as a confirmation that the case is good law; read the citing cases. - Full citator and citing cases: https://www.frixlaw.com/law-library/cases/4476625 ## Opinion text OPINION. OppeR, Judge: These circumstances are indistinguishable from Frank B. Thompson, 42 B. T. A. 121, which has now stood undisturbed by legislative, judicial, or administrative action for upward of 13 years. On the authority of that case, the real property transferred by petitioners to the corporation in which they and their children owned stock is a taxable gift to its full extent. Robert H. Scanlon, 42 B. T. A. 997, which dealt with the transfer to a corporation wholly owned by the transferor is distinguishable from these proceedings on the same grounds as those on which that opinion itself distinguishes the Thompson case. And the transfer to their corporation by petitioners of valuable property is an entirely different thing from the renunciation of the undeclared dividend which occurred in Emily Coles Collins, 1 T. C. 605 . .From Frank B. Thompson, supra, it also follows that each petitioner is entitled to but one exclusion for gift tax purposes for each year. Reviewed by the Court. Decisions will be entered under Bule 50. --- Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/4476625. Public record. Not legal advice.