Seder v. Commissioner
United States Tax Court
H and W transferred stock to a trust, of which H was one of the trustees. Income derived from the stock was to be paid for 3 years to a charitable foundation and then to W for life. No dividend had been paid on the stock in the 11 years preceding the transfer, and there was no reasonable prospect that dividends would be paid in the 3-year period following the transfer.
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H and W transferred stock to a trust, of which H was one of the trustees. Income derived from the stock was to be paid for 3 years to a charitable foundation and then to W for life. No dividend had been paid on the stock in the 11 years preceding the transfer, and there was no reasonable prospect that dividends would be paid in the 3-year period following the transfer. The trustees were empowered to dispose of the stock and to invest the proceeds in income-producing property or to retain it. Held, no charitable deduction is allowed under sec. 170, I.R.C. 1954, because, considering all the…
1Opinion of the Court
Seymour Seder and Frances Seder, Petitioners v. Commissioner of Internal Revenue, Respondent
Seder v. Commissioner
Docket No. 3053-71
United States Tax Court
60 T.C. 49; 1973 U.S. Tax Ct. LEXIS 150; 60 T.C. No. 6;
April 5, 1973April 5, 1973, Filed
Decision will be entered for the respondent.
H and W transferred stock to a trust, of which H was one of the trustees. Income derived from the stock was to be paid for 3 years to a charitable foundation and then to W for life. No dividend had been paid on the stock in the 11 years preceding the transfer, and there was no reasonable prospect that dividends…
2Cases cited13 opinions
- Commissioner v. Estate of SternbergerSupreme Court of the United States · 1955
- Edgar v. CommissionerUnited States Tax Court · 1971
- Morgan v. CommissionerUnited States Tax Court · 1964
- United States v. GatesCourt of Appeals for the Tenth Circuit · 1967
- Darling v. CommissionerUnited States Tax Court · 1965
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