Gershman Family Foundation v. Commissioner
United States Tax Court
In 1971, G sold an apartment building and received a promissory note (AIPN) secured by an all-inclusive deed of trust (AITD) on the building. At the time of sale, the building was encumbered by two prior notes (senior notes) secured by deeds of trust. An addendum to the AITD required G to pay the senior notes and gave the obligor on the AIPN the right to make payments due on the senior notes and offset any such payments against amounts due on the AIPN.
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In 1971, G sold an apartment building and received a promissory note (AIPN) secured by an all-inclusive deed of trust (AITD) on the building. At the time of sale, the building was encumbered by two prior notes (senior notes) secured by deeds of trust. An addendum to the AITD required G to pay the senior notes and gave the obligor on the AIPN the right to make payments due on the senior notes and offset any such payments against amounts due on the AIPN. In 1972, G created a private foundation and was thereafter a "disqualified person" with respect to the foundation and was thus subject to…
1Opinion of the Court
Harold and Julia Gershman Family Foundation, Petitioner v. Commissioner of Internal Revenue, Respondent; Harold Gershman, Petitioner v. Commissioner of Internal Revenue, Respondent
Gershman Family Foundation v. Commissioner
Docket Nos. 16385-81, 16386-81
United States Tax Court
83 T.C. 217; 1984 U.S. Tax Ct. LEXIS 40; 83 T.C. No. 14;
August 15, 1984. August 15, 1984, Filed
In 1971, G sold an apartment building and received a promissory note (AIPN) secured by an all-inclusive deed of trust (AITD) on the building. At the time of sale, the building was encumbered by two prior notes (senior notes)…
2Cases cited7 opinions
- Helvering v. Stockholms Enskilda BankSupreme Court of the United States · 1934
- Stonecrest Corp. v. CommissionerUnited States Tax Court · 1955
- Adams v. CommissionerUnited States Tax Court · 1978
- Goodman v. CommissionerUnited States Tax Court · 1980
- Voight v. CommissionerUnited States Tax Court · 1977
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