Legal Opinion

Hemphill v. Commissioner

United States Tax Court

Decided January 31, 1947No. Docket Nos. 5150, 5151Published

In 1938 petitioner and his wife created irrevocable trusts, of which he was trustee and of which each corpus consisted of 5,000 shares of stock of Aero Industries Technical Institute, Inc. (later merged into Aero-Crafts Corporation). The two minor children of petitioner were beneficiaries, one of each trust. Thereupon, petitioner held a minority of the stock of Industries.

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In 1938 petitioner and his wife created irrevocable trusts, of which he was trustee and of which each corpus consisted of 5,000 shares of stock of Aero Industries Technical Institute, Inc. (later merged into Aero-Crafts Corporation). The two minor children of petitioner were beneficiaries, one of each trust. Thereupon, petitioner held a minority of the stock of Industries. Petitioner became president and a director of Aero-Crafts on December 9, 1940. Under an agreement dated November 14, 1941, petitioner was required to resign as such president and director. Later, with the support of…

1Opinion of the Court

Jane Cooper Hemphill, Petitioner, v. Commissioner of Internal Revenue, Respondent. Ralph Hemphill, Petitioner, v. Commissioner of Internal Revenue, Respondent

Hemphill v. Commissioner

Docket Nos. 5150, 5151

United States Tax Court

8 T.C. 257; 1947 U.S. Tax Ct. LEXIS 295;

January 31, 1947, Promulgated

Decisions will be entered under Rule 50.

In 1938 petitioner and his wife created irrevocable trusts, of which he was trustee and of which each corpus consisted of 5,000 shares of stock of Aero Industries Technical Institute, Inc. (later merged into Aero-Crafts Corporation). The two minor children of…

2Cases cited4 opinions

  1. Helvering v. CliffordSupreme Court of the United States · 1940
  2. Banfield v. CommissionerUnited States Tax Court · 1944
  3. Wheelock v. CommissionerUnited States Tax Court · 1946
  4. Hemphill v. CommissionerUnited States Tax Court · 1947

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