Lazarus v. Commissioner
United States Tax Court
Pursuant to a comprehensive plan developed for them by their attorneys, petitioners, on Apr. 30, 1963, established a foreign situs trust for the benefit of members of their family, and on Dec. 18, 1963, transferred to it their stock in a corporation which owned a shopping center.
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Pursuant to a comprehensive plan developed for them by their attorneys, petitioners, on Apr. 30, 1963, established a foreign situs trust for the benefit of members of their family, and on Dec. 18, 1963, transferred to it their stock in a corporation which owned a shopping center. Purportedly in consideration for the transfer, the trust executed a so-called private annuity agreement providing for the payment of $ 75,000 per year to petitioners, or the survivor of them, for life. As part of the prearrangement, the trust sold the stock to a corporation for a nonnegotiable promissory note,…
1Opinion of the Court
Simon M. Lazarus, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent
Lazarus v. Commissioner
Docket Nos. 4886-69, 4887-69, 4888-69
United States Tax Court
58 T.C. 854; 1972 U.S. Tax Ct. LEXIS 71;
August 17, 1972, Filed
Decisions will be entered under Rule 50.
Pursuant to a comprehensive plan developed for them by their attorneys, petitioners, on Apr. 30, 1963, established a foreign situs trust for the benefit of members of their family, and on Dec. 18, 1963, transferred to it their stock in a corporation which owned a shopping center. Purportedly in consideration for the transfer,…
2Cases cited43 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Helvering v. CliffordSupreme Court of the United States · 1940
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Blair v. CommissionerSupreme Court of the United States · 1937
- Knetsch v. United StatesSupreme Court of the United States · 1960
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