Buehner v. Commissioner
United States Tax Court
Petitioner created four charitable remainder trusts of which he and his wife were trustees and in which they retained a life income interest. Petitioner funded these trusts and claimed a charitable contribution deduction on his individual return for the value of the remainder interest. Included in the assets transferred were limited interests in a partnership created by petitioner and his wife.
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Petitioner created four charitable remainder trusts of which he and his wife were trustees and in which they retained a life income interest. Petitioner funded these trusts and claimed a charitable contribution deduction on his individual return for the value of the remainder interest. Included in the assets transferred were limited interests in a partnership created by petitioner and his wife. The charitable trusts sold their respective assets to a profit-sharing pension trust that was created by a corporation controlled by the petitioner. Petitioner was trustee of the pension trust. These…
1Opinion of the Court
Paul Buehner and Irene Buehner, Petitioners v. Commissioner of Internal Revenue, Respondent
Buehner v. Commissioner
Docket No. 6757-73
United States Tax Court
65 T.C. 723; 1976 U.S. Tax Ct. LEXIS 176;
January 19, 1976, Filed
Decision will be entered for the petitioners.
Petitioner created four charitable remainder trusts of which he and his wife were trustees and in which they retained a life income interest. Petitioner funded these trusts and claimed a charitable contribution deduction on his individual return for the value of the remainder interest. Included in the assets transferred were limited…
2Cases cited28 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Pepper v. LittonSupreme Court of the United States · 1939
- Palmer v. CommissionerUnited States Tax Court · 1974
- Furman v. CommissionerUnited States Tax Court · 1966
- Irvine K. Furman and Lorena K. Furman v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1967
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