Legal Opinion

Wiles v. Commissioner

United States Tax Court

Decided November 21, 1972No. Docket Nos. 146-71, 147-71, 148-71, 149-71Published

P, a physician, and his wife owned two medical office buildings, one of which P used as his office. They transferred the buildings, which were encumbered by a mortgage, to P as trustee for their minor children. The terms of the trust granted P extensive powers, and contemporaneously with the establishment of the trust, he leased the first building from himself as trustee.

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P, a physician, and his wife owned two medical office buildings, one of which P used as his office. They transferred the buildings, which were encumbered by a mortgage, to P as trustee for their minor children. The terms of the trust granted P extensive powers, and contemporaneously with the establishment of the trust, he leased the first building from himself as trustee. As trustee, he also executed leases with the physician and the dentists who occupied the second building, and when additional offices were constructed in such building, P, as trustee, executed a second mortgage on the trust…

1Opinion of the Court

Jack Wiles and Mildred Wiles, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent

Wiles v. Commissioner

Docket Nos. 146-71, 147-71, 148-71, 149-71

United States Tax Court

59 T.C. 289; 1972 U.S. Tax Ct. LEXIS 21;

November 21, 1972, Filed

Decisions will be entered under Rule 50.

P, a physician, and his wife owned two medical office buildings, one of which P used as his office. They transferred the buildings, which were encumbered by a mortgage, to P as trustee for their minor children. The terms of the trust granted P extensive powers, and contemporaneously with the establishment of…

2Cases cited36 opinions

  1. Commissioner v. Estate of BoschSupreme Court of the United States · 1967
  2. Helvering v. CliffordSupreme Court of the United States · 1940
  3. Blair v. CommissionerSupreme Court of the United States · 1937
  4. Douglas v. WillcutsSupreme Court of the United States · 1935
  5. Woods v. SimsTexas Supreme Court · 1954

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