Epstein v. Commissioner
United States Tax Court
By separate declarations of trust made and executed on Sept. 20, 1960, petitioners Harry Epstein and Robert Levitas, the two controlling stockholders of United Management Corp. each created two trusts for the benefit of their children. On that same date, United Management Corp. sold two of its rental properties to the newly created trusts.
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By separate declarations of trust made and executed on Sept. 20, 1960, petitioners Harry Epstein and Robert Levitas, the two controlling stockholders of United Management Corp. each created two trusts for the benefit of their children. On that same date, United Management Corp. sold two of its rental properties to the newly created trusts. Held: 1. The fair market value of the properties sold by United Management Corp. to the trusts exceeded the fair market value of the consideration received by it from such trusts. 2. The difference between the fair market values of the properties sold and…
1Opinion of the Court
Hoyt, Judge:
Respondent determined deficiencies in petitioners’ income and gift tases and additions to tax under section 6651 (a)2 for the taxable year 1960 as follows:
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After various concessions by the parties, the following issues remain for our decision:(1) Whether the fair market value of the property sold by the United Management Corp. exceeded the fair market value of the consideration received by it from the trusts created by the two controlling stockholders of the corporation for their children.(2) If so, whether the difference between the fair market values of the…
2Cases cited10 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Helvering v. CliffordSupreme Court of the United States · 1940
- Danielson v. CommissionerUnited States Tax Court · 1965
- Fischer v. CommissionerUnited States Tax Court · 1968
- O'malley, Collector of Internal Revenue v. AmesCourt of Appeals for the Eighth Circuit · 1952
5 more not listed; retrieve them via the Exa API.
3Cited by45 opinions
- Fehrs v. United StatesUnited States Court of Claims · 1980
- United States v. Marvin MillerCourt of Appeals for the Ninth Circuit · 1976
- Estate of Reynolds v. CommissionerUnited States Tax Court · 1970
- William S. Hagaman, Bonnie C. Hagaman v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1992
- Edgar v. CommissionerUnited States Tax Court · 1971
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