Humphrey v. Commissioner
United States Tax Court
1. In 1957 petitioners established a trust for the benefit of their minor children, which trust was to terminate after 15 years. The trustees, who were nonadverse parties, had the power to accumulate the income of the trust or to expend it for the benefit of petitioners' children. At the termination of the trust, the trust property was to revert to the petitioners.
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1. In 1957 petitioners established a trust for the benefit of their minor children, which trust was to terminate after 15 years. The trustees, who were nonadverse parties, had the power to accumulate the income of the trust or to expend it for the benefit of petitioners' children. At the termination of the trust, the trust property was to revert to the petitioners. Held, the petitioners are to be treated as the owners of the trust within the meaning of section 677(a)(2), I.R.C. 1954. 2. Petitioner Ralph L. Humphrey, together with his brother and his father, owned 100 percent of the stock of X…
1Opinion of the Court
OPINION.
Fay, Judge:
In these consolidated proceedings, respondent determined deficiencies in income tax of $3,001.92 and $4,017.47 for the calendar years 1957 and 1958, respectively.
The only issues for decision are:(1) Whether the petitioners, the grantors of a trust created in 1957, are taxable on the income of said trust for the years 1957 and 1958.(2) Whether the petitioner Ralph L. Humphrey received dividend income in 1957 in the amount of $2,000 as a result of the transfer of his stock in Humphrey Awnings, Inc., to Humphrey Products, Inc.
All of the facts have been stipulated and are found…
2Cases cited7 opinions
- Flanagan v. HelveringCourt of Appeals for the D.C. Circuit · 1940
- Elizabeth N. B. Ferro v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1957
- Decker v. CommissionerUnited States Tax Court · 1959
- Lewis v. CommissionerUnited States Tax Court · 1960
- Hugh H. Earle, Former Collector of Internal Revenue v. Angela MacEvoy WoodlawCourt of Appeals for the Ninth Circuit · 1957
2 more not listed; retrieve them via the Exa API.
3Cited by25 opinions
- Commissioner of Internal Revenue v. John M. Stickney, of the Estate of Henry McK Haserot, and Bonnie C. HaserotCourt of Appeals for the Sixth Circuit · 1968
- Haserot v. CommissionerUnited States Tax Court · 1966
- Fehrs Finance Co. v. CommissionerUnited States Tax Court · 1972
- Levin v. CommissionerUnited States Tax Court · 1966
- Krause v. CommissionerUnited States Tax Court · 1972
20 more not listed; retrieve them via the Exa API.