Brown v. Commissioner
United States Tax Court
In 1962, three general partners, acting individually, formed a total of 12 trusts, each with a fractional interest in the partnership assets, and all of which were identical except in grantor, beneficiary, and size of partnership interest as corpus.
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In 1962, three general partners, acting individually, formed a total of 12 trusts, each with a fractional interest in the partnership assets, and all of which were identical except in grantor, beneficiary, and size of partnership interest as corpus. Simultaneous with the creation of the trusts, the three grantors, as general partners, and the trustee, acting for all of the trusts as limited partners, formed a limited partnership with the assets of the trusts and those interests retained by the grantors. The limited partnership and the trusts were to terminate on Dec. 31, 1972, with the assets…
1Opinion of the Court
Bruce, Judge:
Respondent determined deficiencies in the Federal income taxes for various tax years ending in 1973 of 12 related trusts. Notices of deficiency were sent to the beneficiaries of those trusts on September 21,1978, as alleged transferees of their respective beneficial trusts, as follows:
Settlor Beneficiary /transferee Deficiency Taxable year ending Sec. 6651(a)(1) penalty
Alice F. Brown $3,666.56 6/15/73 $916.64
Jeffrey N. Brown 2,749.94 6/27/73 687.49
Rbbert N. Brown Susan A. Brown 2,749.94 6/11/73 687.49
Rebecca E. Brown 2,749.94 Peggy A. Brown DeClue 6/29/73 2,749.94 6/27/73 687.49…
2Cases cited15 opinions
- Commissioner v. Estate of BoschSupreme Court of the United States · 1967
- Commissioner of Internal Revenue v. Goodwyn Crockery CompanyCourt of Appeals for the Sixth Circuit · 1963
- Young v. BradleySupreme Court of the United States · 1880
- Garth v. CommissionerUnited States Tax Court · 1971
- Goodwyn Crockery Co. v. CommissionerUnited States Tax Court · 1961
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3Cited by1 opinion
- Brown v. CommissionerUnited States Tax Court · 1980