Lerner v. Commissioner
United States Tax Court
Petitioner Hobart A. Lerner, an ophthalmologist, incorporated his practice into Hobart A. Lerner, M.D., P.C. He paid cash for all the issued stock of the corporation. At the same time, he created a trust for the benefit of his children which was to terminate in 10 years and 1 month, and transferred all of his medical equipment and furnishings to the trust. All of the net income of the trust was to be distributed to his children at least annually.
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Petitioner Hobart A. Lerner, an ophthalmologist, incorporated his practice into Hobart A. Lerner, M.D., P.C. He paid cash for all the issued stock of the corporation. At the same time, he created a trust for the benefit of his children which was to terminate in 10 years and 1 month, and transferred all of his medical equipment and furnishings to the trust. All of the net income of the trust was to be distributed to his children at least annually. Upon termination of the trust, the corpus and any accumulated income was to revert to Dr. Lerner. Dr. Lerner's attorney was named trustee. The…
1Opinion of the Court
Drennen, Judge:
In these consolidated cases respondent determined deficiencies as follows:
Docket No. Petitioner Year Deficiency
4267-76 Hobart A. Lerner,
M.D., P.C.FYE Sept. 30, 1971 $2,187.12
FYE Sept. 30, 1972 2,211.51
4268-76 Hobart A. Lerner and
Elinor O. Lerner. 1970 8,171.60
1972 3,213.68
All of the issues raised by the notices of deficiency have been settled by the parties with the following exceptions:(1) Whether rental payments made by a professional corporation to a “Clifford” trust established pursuant to sections 671-678, I.R.C. 1954,1 for the use of equipment donated to the trust by the…
2Cases cited10 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Johnson v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1936
- I. L. Van Zandt and Ruth B. Van Zandt v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1965
- C. James Mathews v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1975
- Mathews v. CommissionerUnited States Tax Court · 1973
5 more not listed; retrieve them via the Exa API.
3Cited by12 opinions
- Metzger Trust v. CommissionerUnited States Tax Court · 1981
- George B. Rosenfeld and Harriet Rosenfeld v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1983
- May v. CommissionerUnited States Tax Court · 1981
- George B. Rosenfeld and Harriet Rosenfeld v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1983
- Lerner v. CommissionerUnited States Tax Court · 1978
7 more not listed; retrieve them via the Exa API.