Legal Opinion

Bennett v. Commissioner

United States Tax Court

Decided September 15, 1982No. Docket Nos. 662-78, 663-78, 664-78Published

A is the father of B and C. A, B, and C were equal partners in a general partnership which engaged in farming and the construction and leasing of nursing homes. On Jan. 1, 1963, A, B, and C created a 13-year trust. The corpus of the trust consisted of the nursing homes which had been owned by the partnership. B's and C's children were the beneficiaries, and B and C were named trustees.

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A is the father of B and C. A, B, and C were equal partners in a general partnership which engaged in farming and the construction and leasing of nursing homes. On Jan. 1, 1963, A, B, and C created a 13-year trust. The corpus of the trust consisted of the nursing homes which had been owned by the partnership. B's and C's children were the beneficiaries, and B and C were named trustees. According to the terms of the trust, all current income was to be distributed to the beneficiaries, at least annually. On the trust's termination, the corpus was to be distributed to the beneficiaries. Contrary…

1Opinion of the Court

O'Neil and Marthann Bennett, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent

Bennett v. Commissioner

Docket Nos. 662-78, 663-78, 664-78

United States Tax Court

79 T.C. 470; 1982 U.S. Tax Ct. LEXIS 40; 79 T.C. No. 30;

September 15, 1982, Filed

Decisions will be entered under Rule 155.

A is the father of B and C. A, B, and C were equal partners in a general partnership which engaged in farming and the construction and leasing of nursing homes. On Jan. 1, 1963, A, B, and C created a 13-year trust. The corpus of the trust consisted of the nursing homes which had been owned by the…

Also in this document: Dissent.

2Cases cited14 opinions

  1. Markosian v. CommissionerUnited States Tax Court · 1980
  2. Furman v. CommissionerUnited States Tax Court · 1966
  3. Irvine K. Furman and Lorena K. Furman v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1967
  4. Commissioner of Internal Revenue v. WhitneyCourt of Appeals for the Second Circuit · 1948
  5. Estate of Gilman v. CommissionerUnited States Tax Court · 1975

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