Wiles v. Commissioner
United States Tax Court
P, a physician, and his wife owned two medical office buildings, one of which P used as his office. They transferred the buildings, which were encumbered by a mortgage, to P as trustee for their minor children. The terms of the trust granted P extensive powers, and contemporaneously with the establishment of the trust, he leased the first building from himself as trustee.
Read the full summary
P, a physician, and his wife owned two medical office buildings, one of which P used as his office. They transferred the buildings, which were encumbered by a mortgage, to P as trustee for their minor children. The terms of the trust granted P extensive powers, and contemporaneously with the establishment of the trust, he leased the first building from himself as trustee. As trustee, he also executed leases with the physician and the dentists who occupied the second building, and when additional offices were constructed in such building, P, as trustee, executed a second mortgage on the trust…
1Opinion of the Court
SimpsON, Judge:
Tbe respondent determined tbe following deficiencies in, and additions to, tbe petitioners’ income tax:
Petitioner Year Deficiency Sec. 6653 (a) [2] addition
[[Image here]]
Most of the issues have been settled, and tbe issues remaining to be decided are: (1) Whether tbe petitioners may deduct as rent certain payments made for tbe use of property which they bad given in trust for their children and which had then been leased back to them, and (2) whether the petitioners are taxable on trust income which was used to make payments on a mortgage for which they were liable.
FINDINGS OF…
2Cases cited35 opinions
- Commissioner v. Estate of BoschSupreme Court of the United States · 1967
- Helvering v. CliffordSupreme Court of the United States · 1940
- Blair v. CommissionerSupreme Court of the United States · 1937
- Douglas v. WillcutsSupreme Court of the United States · 1935
- Woods v. SimsTexas Supreme Court · 1954
30 more not listed; retrieve them via the Exa API.
3Cited by10 opinions
- Anesthesia Service Medical Group, Inc. v. CommissionerUnited States Tax Court · 1985
- Carey J. Perry and Marietta M. Perry v. United States of America, J. Doyle Medders and Constance D. Medders v. United StatesCourt of Appeals for the Fourth Circuit · 1975
- Butler v. CommissionerUnited States Tax Court · 1975
- Wiles v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1974
- Anesthesia Service Medical Group, Inc. v. CommissionerUnited States Tax Court · 1985
5 more not listed; retrieve them via the Exa API.