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
OPINION.
Bettce, Judge:
Under the terms of an agreement executed on December 27, 1949, petitioner Celia Goldstein and her husband, Harry Goldstein, now deceased, transferred certain shares of stock in a family-owned plumbing supply corporation to Joseph Shefner and Harry Gainsley. The announced purpose of the agreement is to preserve the corporation for two of the Goldstein’s children, Bernard and Jerome, who have been active in the business, but at the same time to provide a means by which the other three Goldstein children can obtain in money the book value of three-fifths of all of the…
2Cases cited9 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
4 more not listed; retrieve them via the Exa API.
3Cited by5 opinions
- Thorrez v. CommissionerUnited States Tax Court · 1958
- La Fortune v. CommissionerUnited States Tax Court · 1957
- Goldstein v. CommissionerUnited States Tax Court · 1956
- La Fortune v. CommissionerUnited States Tax Court · 1957
- Thorrez v. CommissionerUnited States Tax Court · 1958