Darryl S. Long and Arlyne M. Long v. Commissioner of Internal Revenue

Darryl S. and Arlyne M. Long appeal from a decision of the Tax Court granting the Commissioner’s motion for summary judgment and upholding the determination of a deficiency in and additions to their federal income tax for 1981 totalling more than $35,000.

The Commissioner based his determination in part on an increase in taxable income due to the disallowance of deductions claimed by the Longs’ family trust. The Commissioner determined that the creation of the trust. The Commissioner determined that the creation of the trust, assignment of income thereto, and claims of deductions by the trust…