Legal Opinion

Carson v. Commissioner

United States Tax Court

Decided May 24, 1989No. Docket No. 45191-85Published

Husband, a self-employed dentist, incorporated his dental practice as a professional corporation. Ps, husband and wife, executed a trust agreement, as grantors, with wife as sole trustee, for the benefit of their two sons. Ps, as co-owners, transferred the real property, equipment, and furnishings used in husband's dental practice to the trust. Thereafter, the corporation leased the real property comprising the dental practice from the trust.

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Husband, a self-employed dentist, incorporated his dental practice as a professional corporation. Ps, husband and wife, executed a trust agreement, as grantors, with wife as sole trustee, for the benefit of their two sons. Ps, as co-owners, transferred the real property, equipment, and furnishings used in husband's dental practice to the trust. Thereafter, the corporation leased the real property comprising the dental practice from the trust. The trust's rental income from the corporation was then distributed to the beneficiaries pursuant to the trust agreement in unequal amounts on an annual…

1Opinion of the Court

John M. Carson and Jean Carson, Petitioners v. Commissioner of Internal Revenue, Respondent

Carson v. Commissioner

Docket No. 45191-85

United States Tax Court

92 T.C. 1134; 1989 U.S. Tax Ct. LEXIS 69; 92 T.C. No. 72;

May 24, 1989. May 24, 1989, Filed

Decision will be entered under Rule 155.

Husband, a self-employed dentist, incorporated his dental practice as a professional corporation. Ps, husband and wife, executed a trust agreement, as grantors, with wife as sole trustee, for the benefit of their two sons. Ps, as co-owners, transferred the real property, equipment, and furnishings used in…

2Cases cited7 opinions

  1. Helvering v. CliffordSupreme Court of the United States · 1940
  2. Commissioner of Internal Revenue v. BuckCourt of Appeals for the Second Circuit · 1941
  3. Stockstrom v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1945
  4. Corning v. CommissionerUnited States Tax Court · 1955
  5. Bennett v. CommissionerUnited States Tax Court · 1982

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