Froh v. Commissioner
United States Tax Court
Petitioner established trusts which provided that the net income less 15 percent be paid to the income beneficiaries for 10 years and 1 month at which time the trusts were to terminate and the principal was to be paid to petitioner or, if he was not living, to his appointees or, in default thereof, to his estate.
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Petitioner established trusts which provided that the net income less 15 percent be paid to the income beneficiaries for 10 years and 1 month at which time the trusts were to terminate and the principal was to be paid to petitioner or, if he was not living, to his appointees or, in default thereof, to his estate. The subject matter of the trusts was property containing gas reserves and a lease of the gas, i.e., a "wasting asset". The parties stipulated the fair market value of the property. Held, in view of the evidence that the gas reserves would be exhausted or reduced to a de minimis level…
1Opinion of the Court
CHARLES T. FROH, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Froh v. Commissioner
Docket No. 23022-90
United States Tax Court
100 T.C. 1; 1993 U.S. Tax Ct. LEXIS 2; 100 T.C. No. 1;
January 7, 1993, Filed
Decision will be entered under Rule 155.
Petitioner established trusts which provided that the net income less 15 percent be paid to the income beneficiaries for 10 years and 1 month at which time the trusts were to terminate and the principal was to be paid to petitioner or, if he was not living, to his appointees or, in default thereof, to his estate. The subject matter of the…
2Cases cited7 opinions
- Weller v. CommissionerUnited States Tax Court · 1962
- Fred A. Berzon v. Commissioner of Internal Revenue, Gertrude Berzon v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1976
- Berzon v. CommissionerUnited States Tax Court · 1975
- Calder v. CommissionerUnited States Tax Court · 1985
- Alma M. O'Reilly v. Commissioner of Internal Revenue, Charles H. O'reilly, Sr. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1992
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