Legal Opinion

Grossman v. Commissioner

United States Tax Court

Decided October 4, 1973No. Docket Nos. 5314-70, 5315-70, 5316-70, 5367-70 thru 5372-70Unpublished

Petitioners executed a contract to purchase property and made the downpayment with 2 borrowed funds. Four days later, the contract was assigned to a charitable family trust, subject to the payment by the trust of the full purchase price. Held, the purchase and subsequent transfer to the charitable family trust were not sham transactions. Held further, the fair market value of the property determined.

1Opinion of the Court

JOSEPH B. GROSSMAN and ESTHER S. GROSSMAN, ET AL., 1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Grossman v. Commissioner

Docket Nos. 5314-70, 5315-70, 5316-70, 5367-70 thru 5372-70.

United States Tax Court

T.C. Memo 1973-219; 1973 Tax Ct. Memo LEXIS 69; 32 T.C.M. (CCH) 1013; T.C.M. (RIA) 73219;

October 4, 1973, Filed

Petitioners executed a contract to purchase property and made the downpayment with 2 borrowed funds. Four days later, the contract was assigned to a charitable family trust, subject to the payment by the trust of the full purchase price. Held, the purchase and…

2Cases cited25 opinions

  1. Gregory v. HelveringSupreme Court of the United States · 1935
  2. Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
  3. Bixby v. CommissionerUnited States Tax Court · 1972
  4. United States v. Cumberland Public Service Co.Supreme Court of the United States · 1950
  5. Kaplan v. CommissionerUnited States Tax Court · 1965

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