Goldstein v. Commissioner
United States Tax Court
Under the terms of a trust created in 1949 by petitioner and her deceased husband for the benefit of their children, stock in a family corporation was transferred to the trustees with the provision that the corporation purchase each year so much of the trust stock as it shall determine and that the trustees will pay over the proceeds of such sale to the beneficiaries. In 1950 and 1951, petitioner contributed shares of stock in the corporation to the trust.
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Under the terms of a trust created in 1949 by petitioner and her deceased husband for the benefit of their children, stock in a family corporation was transferred to the trustees with the provision that the corporation purchase each year so much of the trust stock as it shall determine and that the trustees will pay over the proceeds of such sale to the beneficiaries. In 1950 and 1951, petitioner contributed shares of stock in the corporation to the trust. Held, the gifts of stock in 1950 and 1951 were gifts of future interests within the meaning of section 1003 (b) (3) of the Internal…
1Opinion of the Court
Celia Goldstein, Petitioner, v. Commissioner of Internal Revenue, Respondent
Goldstein v. Commissioner
Docket Nos. 53136, 56173
United States Tax Court
26 T.C. 506; 1956 U.S. Tax Ct. LEXIS 164;
June 12, 1956, Filed
Decision will be entered for the respondent.
Under the terms of a trust created in 1949 by petitioner and her deceased husband for the benefit of their children, stock in a family corporation was transferred to the trustees with the provision that the corporation purchase each year so much of the trust stock as it shall determine and that the trustees will pay over the proceeds of such…
2Cases cited10 opinions
- Fondren v. CommissionerSupreme Court of the United States · 1945
- Fisher v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1942
- Commissioner of Internal Revenue v. SharpCourt of Appeals for the Ninth Circuit · 1946
- Sensenbrenner v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1943
- Welch v. PaineCourt of Appeals for the First Circuit · 1942
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