Estate of Reynolds v. Commissioner
United States Tax Court
Decedents and their family owned virtually all of the units in a voting trust which held a majority of the shares of a stock life insurance company. Under the terms of the voting trust the units could not be sold unless they were first offered to the other holders of units at a formula price based upon the dividends distributed by the company.
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Decedents and their family owned virtually all of the units in a voting trust which held a majority of the shares of a stock life insurance company. Under the terms of the voting trust the units could not be sold unless they were first offered to the other holders of units at a formula price based upon the dividends distributed by the company. If the other unit holders refused the offer, the units would have to be offered a second time to the company's board of directors at the same formula price. The units could be gifted or devised but in the hands of any donee or devisee remained subject…
1Opinion of the Court
Estate of Pearl Gibbons Reynolds, Deceased, Walter Edwin Bixby, Executor, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent
Estate of Reynolds v. Commissioner
Docket Nos. 1577-67, 1578-67, 1579-67, 1605-67, 1606-67
United States Tax Court
55 T.C. 172; 1970 U.S. Tax Ct. LEXIS 36;
October 29, 1970, Filed
Decision will be entered under Rule 50.
Decedents and their family owned virtually all of the units in a voting trust which held a majority of the shares of a stock life insurance company. Under the terms of the voting trust the units could not be sold unless they were first…
2Cases cited55 opinions
- Helvering v. SalvageSupreme Court of the United States · 1936
- Guggenheim v. RasquinSupreme Court of the United States · 1941
- Shomaker v. CommissionerUnited States Tax Court · 1962
- Estate of Reynolds v. CommissionerUnited States Tax Court · 1970
- Clark v. CommissionerUnited States Tax Court · 1952
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