Lazarus v. Commissioner
United States Tax Court
Pursuant to a comprehensive plan developed for them by their attorneys, petitioners, on Apr. 30, 1963, established a foreign situs trust for the benefit of members of their family, and on Dec. 18, 1963, transferred to it their stock in a corporation which owned a shopping center.
Read the full summary
Pursuant to a comprehensive plan developed for them by their attorneys, petitioners, on Apr. 30, 1963, established a foreign situs trust for the benefit of members of their family, and on Dec. 18, 1963, transferred to it their stock in a corporation which owned a shopping center. Purportedly in consideration for the transfer, the trust executed a so-called private annuity agreement providing for the payment of $ 75,000 per year to petitioners, or the survivor of them, for life. As part of the prearrangement, the trust sold the stock to a corporation for a nonnegotiable promissory note,…
1Opinion of the Court
Featheeston, Judge:
Respondent determined tax deficiencies and additions thereto under section 6651 (a) 2 as follows:
Docket No. Kind of tax Year Amount Addition to tax (sec. 6651(a))
488ft-69 . Gift. 1963 $75,644.31 $18,911.08
4887-69 . Gift. 1963 75,644.31 18,911.08
4888-69 fincóme. 1963 7,696.00 . Income. 1964 31,174.00 . [income. 1965 30,175.00 .
In an amendment to answer in docket No. 4888-69, respondent asserted further income tax deficiencies as follows:
Year Amount
1963 _$5,956
1964 _ 32, 889
1965 _ 76, 041
Concessions having been made, the issues remaining for decision are as follows:(1)…
2Cases cited43 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Helvering v. CliffordSupreme Court of the United States · 1940
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Blair v. CommissionerSupreme Court of the United States · 1937
- Knetsch v. United StatesSupreme Court of the United States · 1960
38 more not listed; retrieve them via the Exa API.
3Cited by38 opinions
- Estate of Franklin v. CommissionerUnited States Tax Court · 1975
- Professional Services v. CommissionerUnited States Tax Court · 1982
- Karme v. CommissionerUnited States Tax Court · 1980
- Hill v. CommissionerUnited States Tax Court · 1974
- La Fargue v. CommissionerUnited States Tax Court · 1979
33 more not listed; retrieve them via the Exa API.