Leila G. Newhall Unitrust v. Commissioner
United States Tax Court
P is a charitable remainder unitrust within the meaning of sec. 664(d)(2), I.R.C. P was a shareholder in N, a publicly traded company. In 1983 N underwent a partial liquidation and transferred certain of its assets to two newly formed limited partnerships. In 1983 P received as a distribution from N interests in the two limited partnerships, such interests also being publicly traded.
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P is a charitable remainder unitrust within the meaning of sec. 664(d)(2), I.R.C. P was a shareholder in N, a publicly traded company. In 1983 N underwent a partial liquidation and transferred certain of its assets to two newly formed limited partnerships. In 1983 P received as a distribution from N interests in the two limited partnerships, such interests also being publicly traded. In 1985 N underwent a complete liquidation and transferred its remaining assets to a limited partnership. P, as a shareholder of N, received interests in this third limited partnership in cancellation of its N…
1Opinion of the Court
Leila G. Newhall Unitrust, Wells Fargo Bank, Trustee, Petitioner v. Commissioner of Internal Revenue, Respondent
Leila G. Newhall Unitrust v. Commissioner
Docket No. 10195-93
United States Tax Court
104 T.C. 236; 1995 U.S. Tax Ct. LEXIS 11; 104 T.C. No. 10;
March 6, 1995, Filed
Decision will be entered for respondent.
P is a charitable remainder unitrust within the meaning of sec. 664(d)(2), I.R.C. P was a shareholder in N, a publicly traded company. In 1983 N underwent a partial liquidation and transferred certain of its assets to two newly formed limited partnerships. In 1983 P received as a…
2Cases cited17 opinions
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
- Commissioner v. TowerSupreme Court of the United States · 1946
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- United States v. CorrellSupreme Court of the United States · 1967
- National Muffler Dealers Assn., Inc. v. United StatesSupreme Court of the United States · 1979
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