Estate of Paxton v. Commissioner
United States Tax Court
During his lifetime, decedent created two trusts to which he and his spouse transferred, in exchange for certificates of beneficial interest in the trusts, their residence, stock in several corporations, patents, and virtually all other property they owned except a patent royalty agreement with one of their corporations. They later transferred some of their certificates to other family members.
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During his lifetime, decedent created two trusts to which he and his spouse transferred, in exchange for certificates of beneficial interest in the trusts, their residence, stock in several corporations, patents, and virtually all other property they owned except a patent royalty agreement with one of their corporations. They later transferred some of their certificates to other family members. Decedent's son, his accountant, his attorney, and other close associates served as trustees. Under the terms of the trust instruments, the trustees were given full discretionary power to distribute the…
1Opinion of the Court
FEATHERSTON, Judge:
Respondent determined a deficiency in the amount of $11,738,717 in the estate tax for the estate of Floyd G. Paxton and an addition to tax under section 6651(a)(1)2 in the amount of $2,934,679. Also, respondent determined that the trustees of two trusts, the F.G. Paxton Family Organization Trust and the International Development Trust, are liable as transferees for the estate tax and additions to tax under sections 6324 and 6901.
The following issues have been severed for separate trial and decision:(1) Whether the gross estate of Floyd G. Paxton includes, under sections…
2Cases cited63 opinions
- Commissioner v. Estate of BoschSupreme Court of the United States · 1967
- United States v. BoyleSupreme Court of the United States · 1985
- Estate of Sanford v. CommissionerSupreme Court of the United States · 1939
- George v. Zmuda and Walburga Zmuda v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1984
- Commissioner v. Estate of ChurchSupreme Court of the United States · 1949
58 more not listed; retrieve them via the Exa API.
3Cited by29 opinions
- Crocker v. CommissionerUnited States Tax Court · 1989
- Estate of La Meres v. Comm'rUnited States Tax Court · 1992
- Estate of Reichardt v. CommissionerUnited States Tax Court · 2000
- Lilley v. CommissionerUnited States Tax Court · 1989
- Estate of Wilbanks v. CommissionerUnited States Tax Court · 1990
24 more not listed; retrieve them via the Exa API.