Carson v. Commissioner
United States Tax Court
Husband, a self-employed dentist, incorporated his dental practice as a professional corporation. Ps, husband and wife, executed a trust agreement, as grantors, with wife as sole trustee, for the benefit of their two sons. Ps, as co-owners, transferred the real property, equipment, and furnishings used in husband's dental practice to the trust. Thereafter, the corporation leased the real property comprising the dental practice from the trust.
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Husband, a self-employed dentist, incorporated his dental practice as a professional corporation. Ps, husband and wife, executed a trust agreement, as grantors, with wife as sole trustee, for the benefit of their two sons. Ps, as co-owners, transferred the real property, equipment, and furnishings used in husband's dental practice to the trust. Thereafter, the corporation leased the real property comprising the dental practice from the trust. The trust's rental income from the corporation was then distributed to the beneficiaries pursuant to the trust agreement in unequal amounts on an annual…
1Opinion of the Court
NlMS, Chief Judge:
Respondent determined the following deficiencies and additions to tax:
Additions to tax
Year Deficiency Sec. 6653(a)1 Sec. 6661
1981 $10,317.45 $516
1982 6,151.04 308 $615
1983 6,533.60 327 653
Before trial, petitioners conceded the 1981 deficiency and respondent conceded all of the determined additions to tax under sections 6653(a) and 6661. Respondent filed a motion to amend the pleadings after trial, wherein he moved, pursuant to section 6214(a), that the deficiency for the taxable year 1983 be increased from $6,533.60 to $6,962. Petitioners filed no objection and we granted…
2Cases cited6 opinions
- Helvering v. CliffordSupreme Court of the United States · 1940
- Commissioner of Internal Revenue v. BuckCourt of Appeals for the Second Circuit · 1941
- Stockstrom v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1945
- Corning v. CommissionerUnited States Tax Court · 1955
- Bennett v. CommissionerUnited States Tax Court · 1982
1 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Carson v. CommissionerUnited States Tax Court · 1989