Berzon v. Commissioner
United States Tax Court
Petitioner Fred A. Berzon transferred stock of the Simons Co. to trusts for the benefit of his children and grandchildren in each of the years 1962 through 1968. The stock was subject to certain restrictions on transfer, there being a right of the corporation or the other stockholders thereof to purchase all the stock of any stockholder proposing any transfer during life, except to certain relatives, and a mandatory buy-sell agreement with the corporation or other…
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Petitioner Fred A. Berzon transferred stock of the Simons Co. to trusts for the benefit of his children and grandchildren in each of the years 1962 through 1968. The stock was subject to certain restrictions on transfer, there being a right of the corporation or the other stockholders thereof to purchase all the stock of any stockholder proposing any transfer during life, except to certain relatives, and a mandatory buy-sell agreement with the corporation or other stockholders at death at yearly agreed-upon prices. Income of the trusts for the adult beneficiaries was to be paid at least…
1Opinion of the Court
Sterrett, Judge:
The respondent determined deficiencies in the Federal gift taxes of petitioners as follows:
Petitioner Docket No. Year Deficiency
Fred A. Berzon 8615-71 1965 $4,757.58
1966 4,384.80
1967 5,170.17
1968 5,877.00
Gertrude Berzon 8616-71 1965 4,757.58
1966 4,384.80
1967 5,170.17
1968 5,877.00
The issues for decision are: (1) The valuation of the stock of the Simons Co., Inc., which was transferred to eight trusts during the years in issue; (2) whether each petitioner is entitled to a $3,000 exclusion under section 2503, I.R.C. 1954,1 for transfers of the Simons Co., Inc., stock to each of…
2Cases cited29 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- United States v. PelzerSupreme Court of the United States · 1941
- Fondren v. CommissionerSupreme Court of the United States · 1945
- Commissioner v. DisstonSupreme Court of the United States · 1945
- Helvering v. HutchingsSupreme Court of the United States · 1941
24 more not listed; retrieve them via the Exa API.
3Cited by31 opinions
- Harwood v. CommissionerUnited States Tax Court · 1984
- Ward v. CommissionerUnited States Tax Court · 1986
- Estate of Gribauskas v. CommissionerUnited States Tax Court · 2001
- Calder v. CommissionerUnited States Tax Court · 1985
- Alma M. O'Reilly v. Commissioner of Internal Revenue, Charles H. O'reilly, Sr. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1992
26 more not listed; retrieve them via the Exa API.