Estate of Schutt v. Comm'r
United States Tax Court
S1 and S2, Delaware business trusts, were formed in 1998 and were capitalized by the contribution thereto of stock by D through a revocable trust and by WTC as trustee of various trusts created for the benefit of D's children and grandchildren.
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S1 and S2, Delaware business trusts, were formed in 1998 and were capitalized by the contribution thereto of stock by D through a revocable trust and by WTC as trustee of various trusts created for the benefit of D's children and grandchildren. At his death in 1999, D held through the revocable trust a 45.236-percent interest in S1 and a 47.336- percent interest in S2. Held: D's transfers of stock to S1 and S2 were bona fide sales for adequate and full consideration within the meaning of secs. 2036(a) and 2038, I.R.C., such that the value of the transferred assets is not included in his gross…
1Opinion of the Court
ESTATE OF CHARLES PORTER SCHUTT, DECEASED, CHARLES P. SCHUTT, JR., AND HENRY I. BROWN III, CO-EXECUTORS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Estate of Schutt v. Comm'r
No. 19208-02
United States Tax Court
T.C. Memo 2005-126; 2005 Tax Ct. Memo LEXIS 126; 89 T.C.M. (CCH) 1353;
May 26, 2005, Filed
S1 and S2, Delaware business trusts, were formed in 1998
and were capitalized by the contribution thereto of stock by D
through a revocable trust and by WTC as trustee of various
trusts created for the benefit of D's children and
grandchildren. At his death in 1999, D held through the
revoca…
2Cases cited13 opinions
- United States v. ByrumSupreme Court of the United States · 1972
- United States v. Estate of GraceSupreme Court of the United States · 1969
- Estate of Daniel McNichol Deceased, Ellen McNichol Evangelista and Joseph G. McNichol Executors v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1959
- Estate of Bongard v. Comm'rUnited States Tax Court · 2005
- Jane C. Guynn, of the Estate of Vena E. Calvert, Deceased v. United StatesCourt of Appeals for the Fourth Circuit · 1971
8 more not listed; retrieve them via the Exa API.
3Cited by10 opinions
- Estate of Black v. Comm'rUnited States Tax Court · 2009
- Holman v. CommissionerCourt of Appeals for the Eighth Circuit · 2010
- Estate of Turner v. Comm'rUnited States Tax Court · 2012
- Estate of Rosen v. Comm'rUnited States Tax Court · 2006
- Estate of Stone v. Comm'rUnited States Tax Court · 2012
5 more not listed; retrieve them via the Exa API.