Estate of Cohen v. Commissioner
United States Tax Court
Over a period of about 28 months ending some 4 years prior to his death, the decedent transferred all of his common shares and 7,350 of his 7,500 preferred shares in a Massachusetts real estate trust to his children, grandchildren, and great-grandchildren. The primary function of the trust was to lease a store facility to the corporate retail business operated by the decedent and his three sons.
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Over a period of about 28 months ending some 4 years prior to his death, the decedent transferred all of his common shares and 7,350 of his 7,500 preferred shares in a Massachusetts real estate trust to his children, grandchildren, and great-grandchildren. The primary function of the trust was to lease a store facility to the corporate retail business operated by the decedent and his three sons. The decedent and his sons were the trustees of the trust when the transfers were made and at all times thereafter until the death of the decedent. Held: The discretion accorded the trustees in the…
1Opinion of the Court
Estate of Abraham Cohen, Deceased, Maurice M. Cohen, William P. Cohen and Norman D. Cohen, Executors, Petitioner v. Commissioner of Internal Revenue, Respondent
Estate of Cohen v. Commissioner
Docket No. 21028-80
United States Tax Court
79 T.C. 1015; 1982 U.S. Tax Ct. LEXIS 4; 79 T.C. No. 65;
December 20, 1982, Filed
Decision will be entered under Rule 155.
Over a period of about 28 months ending some 4 years prior to his death, the decedent transferred all of his common shares and 7,350 of his 7,500 preferred shares in a Massachusetts real estate trust to his children, grandchildren, and…
2Cases cited13 opinions
- Morrissey v. CommissionerSupreme Court of the United States · 1935
- Helvering v. Coleman-Gilbert AssociatesSupreme Court of the United States · 1935
- United States v. ByrumSupreme Court of the United States · 1972
- Swanson v. CommissionerSupreme Court of the United States · 1935
- Hynes v. CommissionerUnited States Tax Court · 1980
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