D. Clifford Crummey v. Commissioner of Internal Revenue

BYRNE, District Judge:

This case involves cross petitions for review of decisions of the Tax Court of the United States. Jurisdiction in the Tax Court was based upon 26 U.S.C. § 7442. Jurisdiction in this court is based upon 26 U.S.C. §§ 7482 and 7483.

On February 12, 1962, the petitioners executed, as grantors, an irrevocable living trust for the benefit of their four children. The beneficiaries and their ages at relevant times are as follows:

John Knowles Crummey

Janet Sheldon Crummey

David Clarke Crummey

Mark Clifford Crummey

Age 12/31/62 12/31/63

22 23

20 21

15 16

11 12

Originally the sum of $50 was…