Makransky v. Commissioner
United States Tax Court
The settlor of a trust transferred all the capital stock of a wholly owned corporation to the trust for the benefit of his four daughters. The settlor, the four daughters, and three others were trustees. The transfer rendered the settlor insolvent because of a substantial obligation arising from a judgment in favor of the Commonwealth of Pennsylvania. The Commonwealth threatened the trust assets under the Pennsylvania Fraudulent Conveyance Act.
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The settlor of a trust transferred all the capital stock of a wholly owned corporation to the trust for the benefit of his four daughters. The settlor, the four daughters, and three others were trustees. The transfer rendered the settlor insolvent because of a substantial obligation arising from a judgment in favor of the Commonwealth of Pennsylvania. The Commonwealth threatened the trust assets under the Pennsylvania Fraudulent Conveyance Act. The trust, with the approval of a State court, caused the corporation to make distributions to the settlor, and after his demise, to his estate. The…
1Opinion of the Court
Harry Makransky and Helen Makransky, et al., 1 Petitioners, v. Commissioner of Internal Revenue, Respondent
Makransky v. Commissioner
Docket Nos. 83212, 83356, 83357, 83463, 83464, 86007, 86008, 86381, 86490
United States Tax Court
36 T.C. 446; 1961 U.S. Tax Ct. LEXIS 135;
May 29, 1961, Filed
Decisions will be entered for the petitioners in Docket Nos. 83356 and 83357. Decisions will be entered for the respondent in Docket Nos. 83463 and 86490. Decisions will be entered under Rule 50 in Docket Nos. 83212, 83464, 86007, 86008, and 86381.
The settlor of a trust transferred all the capital stock of a…
2Cases cited11 opinions
- Irving Sachs v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1960
- Baird v. CommissionerUnited States Tax Court · 1955
- Sachs v. CommissionerUnited States Tax Court · 1959
- Fidelity Trust Co. v. Union National BankSupreme Court of Pennsylvania · 1933
- Tucker v. BinenstockSupreme Court of Pennsylvania · 1932
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