Busch v. Commissioner
United States Tax Court
Petitioners are beneficiaries of certain trusts the income of which is payable to them upon request. The settlor of such trusts wished to make additional gifts thereto of certain shares having a value of $ 2,800,000, but was unable to pay the $ 600,000 in gift taxes which would be due thereon and was unwilling to become personally liable on any indebtedness therefor. A bank agreed to loan $ 600,000 on the sole security of the shares.
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Petitioners are beneficiaries of certain trusts the income of which is payable to them upon request. The settlor of such trusts wished to make additional gifts thereto of certain shares having a value of $ 2,800,000, but was unable to pay the $ 600,000 in gift taxes which would be due thereon and was unwilling to become personally liable on any indebtedness therefor. A bank agreed to loan $ 600,000 on the sole security of the shares. Accordingly the settlor-donor transferred the shares in varying amounts to the several trusts, borrowed $ 600,000 from the bank, payable in 5 years, and executed…
1Opinion of the Court
Adolphus Busch, III, Petitioner, et al., 1 v. Commissioner of Internal Revenue, Respondent
Busch v. Commissioner
Docket Nos. 2078, 2079, 2080, 2081, 2082, 2083, 2084, 2085, 2086, 2087, 2088
United States Tax Court
3 T.C. 547; 1944 U.S. Tax Ct. LEXIS 157;
March 31, 1944, Promulgated
Decision will be entered under Rule 50.
Petitioners are beneficiaries of certain trusts the income of which is payable to them upon request. The settlor of such trusts wished to make additional gifts thereto of certain shares having a value of $ 2,800,000, but was unable to pay the $ 600,000 in gift taxes which would be…
2Cases cited8 opinions
- Helvering v. HorstSupreme Court of the United States · 1940
- Corliss v. BowersSupreme Court of the United States · 1930
- Farmers' & Merchants' National Bank v. MosherNebraska Supreme Court · 1901
- Guarantee Co. of North America v. East Rome Town Co.Supreme Court of Georgia · 1895
- Gaty v. HollidayMissouri Court of Appeals · 1879
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