Richard R. Quinlivan and Ann M. Quinlivan, Roger P. Quinlivan and Joyce E. Quinlivan v. Commissioner of Internal Revenue

GIBSON, Chief Judge.

The Government appeals from a decision of the Tax Court 1 holding that Richard and Roger Quinlivan 2 are entitled to deduct rental payments made to a short-term, so-called Clifford trust set up in accordance with sections 671 through 678 of the Internal Revenue Code of 1954, 26 U.S.C. §§ 671-678. The payments were made for the use of an office building previously owned by the taxpayers and transferred by them to a trustee for the benefit of the taxpayers’ children, ^fter carefully considering the arguments of the parties and the pertinent statutory and case authority, we…