Legal Opinion

Estate of Paxton v. Commissioner

United States Tax Court

Decided April 28, 1986No. Docket Nos. 5044-82, 17718-83, 17728-83Published

During his lifetime, decedent created two trusts to which he and his spouse transferred, in exchange for certificates of beneficial interest in the trusts, their residence, stock in several corporations, patents, and virtually all other property they owned except a patent royalty agreement with one of their corporations. They later transferred some of their certificates to other family members.

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During his lifetime, decedent created two trusts to which he and his spouse transferred, in exchange for certificates of beneficial interest in the trusts, their residence, stock in several corporations, patents, and virtually all other property they owned except a patent royalty agreement with one of their corporations. They later transferred some of their certificates to other family members. Decedent's son, his accountant, his attorney, and other close associates served as trustees. Under the terms of the trust instruments, the trustees were given full discretionary power to distribute the…

1Opinion of the Court

Estate of Floyd G. Paxton, Jerre Paxton, Personal Representative; F.G. Paxton Family Organization Trust, Jerre Paxton, Trustee; International Development Trust, Jerre Paxton, Trustee, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent

Estate of Paxton v. Commissioner

Docket Nos. 5044-82, 17718-83, 17728-83

United States Tax Court

86 T.C. 785; 1986 U.S. Tax Ct. LEXIS 113; 86 T.C. No. 51;

April 28, 1986, Filed

During his lifetime, decedent created two trusts to which he and his spouse transferred, in exchange for certificates of beneficial interest in the trusts, their residence,…

2Cases cited63 opinions

  1. Commissioner v. Estate of BoschSupreme Court of the United States · 1967
  2. United States v. BoyleSupreme Court of the United States · 1985
  3. Estate of Sanford v. CommissionerSupreme Court of the United States · 1939
  4. George v. Zmuda and Walburga Zmuda v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1984
  5. Commissioner v. Estate of ChurchSupreme Court of the United States · 1949

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