Gordon v. Commissioner
United States Tax Court
Petitioner husband and petitioner wife, the latter as trustee of a trust established by petitioner husband for the benefit of petitioners' children, entered into joint purchase agreements whereby, in form, petitioner husband purchased income interests for life, and the trust purchased remainder interests, in certain bonds. Petitioner husband entered into a similar agreement with himself as trustee of a pension trust for the benefit of his employees.
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Petitioner husband and petitioner wife, the latter as trustee of a trust established by petitioner husband for the benefit of petitioners' children, entered into joint purchase agreements whereby, in form, petitioner husband purchased income interests for life, and the trust purchased remainder interests, in certain bonds. Petitioner husband entered into a similar agreement with himself as trustee of a pension trust for the benefit of his employees. Held, because, in substance, petitioner husband purchased the bonds in their entirety, petitioners' amortization deductions for the cost of the…
1Opinion of the Court
Everett J. Gordon and Marian K. Gordon, Petitioners v. Commissioner of Internal Revenue, Respondent
Gordon v. Commissioner
Docket No. 28805-82
United States Tax Court
85 T.C. 309; 1985 U.S. Tax Ct. LEXIS 47; 85 T.C. No. 18;
August 20, 1985, Filed
Decision will be entered under Rule 155.
Petitioner husband and petitioner wife, the latter as trustee of a trust established by petitioner husband for the benefit of petitioners' children, entered into joint purchase agreements whereby, in form, petitioner husband purchased income interests for life, and the trust purchased remainder interests, in certain…
2Cases cited44 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Helvering v. CliffordSupreme Court of the United States · 1940
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Griffiths v. CommissionerSupreme Court of the United States · 1939
- Professional Services v. CommissionerUnited States Tax Court · 1982
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