Estate of Bischoff v. Commissioner
United States Tax Court
Within a very short time period, Bruno and Bertha Bischoff each created identical trusts for their joint grandchildren, naming each other as trustee. On Bruno's and Bertha's deaths, held, the corpora of such trusts are includable in their estates. Held, further: On the facts, the estate tax valuation of decedents' interests in certain partnerships is limited by the restrictive buy-sell provisions to which the interests were subject at death.
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Within a very short time period, Bruno and Bertha Bischoff each created identical trusts for their joint grandchildren, naming each other as trustee. On Bruno's and Bertha's deaths, held, the corpora of such trusts are includable in their estates. Held, further: On the facts, the estate tax valuation of decedents' interests in certain partnerships is limited by the restrictive buy-sell provisions to which the interests were subject at death. The value of another limited partnership interest is determined, applying a discount from asset value for minority ownership.
1Opinion of the Court
Estate of Bruno Bischoff, Deceased, Herbert Bischoff and Alvina L. Martin, Executors, Petitioner v. Commissioner of Internal Revenue, Respondent; Estate of Bertha Bischoff, Deceased, Herbert Bischoff and Alvina L. Martin, Executors, Petitioner v. Commissioner of Internal Revenue, Respondent
Estate of Bischoff v. Commissioner
Docket Nos. 312-72, 1035-73
United States Tax Court
69 T.C. 32; 1977 U.S. Tax Ct. LEXIS 37;
October 20, 1977, Filed
Decisions will be entered under Rule 155.
Within a very short time period, Bruno and Bertha Bischoff each created identical trusts for their joint grandchildren,…
Also in this document: Concurrence; Dissent.
2Cases cited29 opinions
- Orvis v. HigginsCourt of Appeals for the Second Circuit · 1950
- Lehman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1940
- United States v. Estate of GraceSupreme Court of the United States · 1969
- United States v. O'MALLEYSupreme Court of the United States · 1966
- Lober v. United StatesSupreme Court of the United States · 1953
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