Legal Opinion

Archbishop Samuel Trust v. Commissioner

United States Tax Court

Decided June 30, 1961No. Docket Nos. 79946, 79947PublishedCited by 21 opinions

In 1951 Athanasius Y. Samuel transferred the Dead Sea Scrolls in trust reserving to himself all the income therefrom and 90 percent of the principal for life.

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In 1951 Athanasius Y. Samuel transferred the Dead Sea Scrolls in trust reserving to himself all the income therefrom and 90 percent of the principal for life. In 1952 Samuel amended the trust, directing the trust to pay him $ 30,000 to compensate him for his expenses relative to the scrolls and to further make annual payments to him of $ 10,000 from principal or income for life, and upon his death payments to his mother for her life in amounts determined by the trustees but not to exceed $ 2,500 annually. In 1954 the trust sold the scrolls for $ 250,000. Held: 1. The transfer of the Dead Sea…

1Opinion of the Court

Scott, Judge:

The respondent determined deficiencies in income tax against Archbishop Samuel Trust in the amounts of $61,879.74, $818.86, and $239.14 for the years 1954, 1955, and 1956, respectively, and an addition to the tax under section 6653(a) of the Internal Revenue Code of 1954 in the amount of $3,093.99 for the year 1954. The respondent also determined deficiencies of $61,818.33 and $157.64 for the years 1954 and 1955 in the income tax of petitioner Athanasius Y. Samuel and additions to the tax for 1954 under sections 294(d)(1)(A) and 294(d) (2) of the Internal Revenue Code of 1939 and…

2Cases cited7 opinions

  1. Bergan v. CommissionerUnited States Tax Court · 1943
  2. Pittman v. CommissionerUnited States Tax Court · 1950
  3. Estate of Maria Becklenberg, Deceased, Fred Becklenberg, Jr. v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1959
  4. Helvering v. EvansCourt of Appeals for the Third Circuit · 1942
  5. Kent v. RothensiesCourt of Appeals for the Third Circuit · 1941

2 more not listed; retrieve them via the Exa API.

3Cited by21 opinions

  1. Edgar v. CommissionerUnited States Tax Court · 1971
  2. Lazarus v. CommissionerUnited States Tax Court · 1972
  3. La Fargue v. CommissionerUnited States Tax Court · 1979
  4. Smith v. CommissionerUnited States Tax Court · 1971
  5. Stern v. CommissionerUnited States Tax Court · 1981

16 more not listed; retrieve them via the Exa API.

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