Horstmier v. Commissioner
United States Tax Court
Pursuant to P's request, P's brother executed a power of attorney appointing X to act as his lawful attorney in connection with the creation of a foreign situs trust with ABC Trust Co. as trustee.
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Pursuant to P's request, P's brother executed a power of attorney appointing X to act as his lawful attorney in connection with the creation of a foreign situs trust with ABC Trust Co. as trustee. X, acting as the lawful attorney of P's brother, executed an irrevocable trust instrument, dated April 24, 1967, for the benefit of P, P's children, and P's grandchildren, which provided, inter alia, that P's brother, as trustor, had delivered to ABC Trust Co. $100 as the initial corpus of the trust. On May 1, 1967, X, acting as P's lawful attorney, executed an "Annuity Agreement" stating that P was…
1Opinion of the Court
ARTHUR W. HORSTMIER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Horstmier v. Commissioner
Docket Nos. 5644-72, 9796-74, 6544-78, 8193-79.
United States Tax Court
T.C. Memo 1983-409; 1983 Tax Ct. Memo LEXIS 374; 46 T.C.M. (CCH) 738; T.C.M. (RIA) 83409;
July 18, 1983; As Amended July 27, 1983
Pursuant to P's request, P's brother executed a power of attorney appointing X to act as his lawful attorney in connection with the creation of a foreign situs trust with ABC Trust Co. as trustee. X, acting as the lawful attorney of P's brother, executed an irrevocable trust instrument, dated…
2Cases cited41 opinions
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