Berzon v. Commissioner
United States Tax Court
Petitioner Fred A. Berzon transferred stock of the Simons Co. to trusts for the benefit of his children and grandchildren in each of the years 1962 through 1968. The stock was subject to certain restrictions on transfer, there being a right of the corporation or the other stockholders thereof to purchase all the stock of any stockholder proposing any transfer during life, except to certain relatives, and a mandatory buy-sell agreement with the corporation or other…
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Petitioner Fred A. Berzon transferred stock of the Simons Co. to trusts for the benefit of his children and grandchildren in each of the years 1962 through 1968. The stock was subject to certain restrictions on transfer, there being a right of the corporation or the other stockholders thereof to purchase all the stock of any stockholder proposing any transfer during life, except to certain relatives, and a mandatory buy-sell agreement with the corporation or other stockholders at death at yearly agreed-upon prices. Income of the trusts for the adult beneficiaries was to be paid at least…
1Opinion of the Court
Fred A. Berzon, Petitioner v. Commissioner of Internal Revenue, Respondent; Gertrude Berzon, Petitioner v. Commissioner of Internal Revenue, Respondent
Berzon v. Commissioner
Docket Nos. 8615-71, 8616-71
United States Tax Court
63 T.C. 601; 1975 U.S. Tax Ct. LEXIS 186;
March 11, 1975, Filed
Decisions will be entered under Rule 155.
Petitioner Fred A. Berzon transferred stock of the Simons Co. to trusts for the benefit of his children and grandchildren in each of the years 1962 through 1968. The stock was subject to certain restrictions on transfer, there being a right of the corporation or the other…
2Cases cited30 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- United States v. PelzerSupreme Court of the United States · 1941
- Fondren v. CommissionerSupreme Court of the United States · 1945
- Commissioner v. DisstonSupreme Court of the United States · 1945
- Helvering v. HutchingsSupreme Court of the United States · 1941
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