Legal Opinion

Mathews v. Commissioner

United States Tax Court

Decided October 3, 1973No. Docket No. 4401-69Published

1. Petitioners, husband and wife, created several 10-year trusts for the benefit of their minor children to which they transferred property used in the husband's trade or business, which he in turn leased back from the trusts.

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1. Petitioners, husband and wife, created several 10-year trusts for the benefit of their minor children to which they transferred property used in the husband's trade or business, which he in turn leased back from the trusts. Held, on the facts, the rentals paid constitute ordinary and necessary business expenses, and petitioners' reversionary interest was not a disqualifying "equity" in the property within the meaning of sec. 162(a)(3) and did not preclude petitioners from deducting the reasonable rent paid to the trusts for the use and possession of the term-of-years held by the trusts. 2.…

1Opinion of the Court

C. James Mathews and Joyce C. Mathews, Petitioners v. Commissioner of Internal Revenue, Respondent

Mathews v. Commissioner

Docket No. 4401-69

United States Tax Court

61 T.C. 12; 1973 U.S. Tax Ct. LEXIS 43; 61 T.C. No. 3;

October 3, 1973, Filed

Decision will be entered under Rule 50.

1. Petitioners, husband and wife, created several 10-year trusts for the benefit of their minor children to which they transferred property used in the husband's trade or business, which he in turn leased back from the trusts. Held, on the facts, the rentals paid constitute ordinary and necessary business expenses, and…

Also in this document: Dissent.

2Cases cited34 opinions

  1. Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
  2. Walburga Oesterreich v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1955
  3. Furman v. CommissionerUnited States Tax Court · 1966
  4. Irvine K. Furman and Lorena K. Furman v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1967
  5. Mills v. CommissionerUnited States Tax Court · 1948

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