Palmer v. Commissioner
United States Tax Court
1. Palmer College was owned and operated by a profit-making corporation. The assets of the college comprised approximately 80 percent of the assets of the corporation. Approximately 70 percent of the outstanding shares of the corporation stock was owned by a trust of which the petitioner was trustee and income beneficiary. The remaining shares were owned outright by the petitioner.
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1. Palmer College was owned and operated by a profit-making corporation. The assets of the college comprised approximately 80 percent of the assets of the corporation. Approximately 70 percent of the outstanding shares of the corporation stock was owned by a trust of which the petitioner was trustee and income beneficiary. The remaining shares were owned outright by the petitioner. On Aug. 31, 1966, a charitable organization, of which the petitioner was controlling trustee, purchased the shares owned by the trust. On the same day, the petitioner contributed enough shares to the foundation so…
1Opinion of the Court
Daniel D. Palmer and Agnes H. Palmer, Petitioners v. Commissioner of Internal Revenue, Respondent
Palmer v. Commissioner
Docket No. 2557-71
United States Tax Court
62 T.C. 684; 1974 U.S. Tax Ct. LEXIS 57; 62 T.C. No. 75;
August 27, 1974, Filed
Decision will be entered for the petitioners.
1. Palmer College was owned and operated by a profit-making corporation. The assets of the college comprised approximately 80 percent of the assets of the corporation. Approximately 70 percent of the outstanding shares of the corporation stock was owned by a trust of which the petitioner was trustee and income…
2Cases cited75 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Helvering v. CliffordSupreme Court of the United States · 1940
- Lucas v. EarlSupreme Court of the United States · 1930
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
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