Estate of Du Pont v. Commissioner
United States Tax Court
1. D, who was then 65 years old, conveyed all but 18 acres of his 260-acre residential and recreational estate (Bellevue Hall) to his wholly owned corporation (Hall, Inc.) which had been created for that purpose. The portion thus transferred was used by him to train racehorses.
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1. D, who was then 65 years old, conveyed all but 18 acres of his 260-acre residential and recreational estate (Bellevue Hall) to his wholly owned corporation (Hall, Inc.) which had been created for that purpose. The portion thus transferred was used by him to train racehorses. He shortly thereafter leased the property from his corporation at a rent based upon not more than one-quarter to one-third of the property's fair market value for a term of 10 years with an option to renew for successive 10-year terms. The rental was based upon the use of the property as a "horse farm," whereas the…
1Opinion of the Court
Estate of William du Pont, Jr., Deceased, Jean Ellen du Pont McConnell, William S. Potter, and Delaware Trust Company, as Executors, Petitioners v. Commissioner of Internal Revenue, Respondent
Estate of Du Pont v. Commissioner
Docket No. 2926-70
United States Tax Court
63 T.C. 746; 1975 U.S. Tax Ct. LEXIS 170;
March 31, 1975, Filed
Decision to be entered under Rule 155.
1. D, who was then 65 years old, conveyed all but 18 acres of his 260-acre residential and recreational estate (Bellevue Hall) to his wholly owned corporation (Hall, Inc.) which had been created for that purpose. The portion thus…
2Cases cited18 opinions
- Commissioner v. Estate of BoschSupreme Court of the United States · 1967
- Commissioner v. Estate of ChurchSupreme Court of the United States · 1949
- United States v. ByrumSupreme Court of the United States · 1972
- United States v. Estate of GraceSupreme Court of the United States · 1969
- United States v. O'MALLEYSupreme Court of the United States · 1966
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