Estate of Sheaffer v. Commissioner
United States Tax Court
In 1954 petitioners transferred 70,000 shares of S Corporation stock to four irrevocable trusts they created for their children. In 1955, pursuant to the trust agreement, the corporate trustee timely paid petitioners' 1954 gift tax liability out of accumulated trust income and funds borrowed on the security of the trust corpus.
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In 1954 petitioners transferred 70,000 shares of S Corporation stock to four irrevocable trusts they created for their children. In 1955, pursuant to the trust agreement, the corporate trustee timely paid petitioners' 1954 gift tax liability out of accumulated trust income and funds borrowed on the security of the trust corpus. Held, that the 1956 trust income used by the trustee to pay the balance of the 1955 loan is not taxable to petitioners under sec. 677(a), I.R.C. 1954. Estate of Annette S. Morgan, 37 T.C. 981 (1962), affirmed per curiam 316 F. 2d 238 (C.A. 6, 1963), certiorari denied…
1Opinion of the Court
Estate of Craig R. Sheaffer, Deceased, and Estate of Virginia D. Sheaffer, Deceased, Walter A. Sheaffer, II, and John D. Sheaffer v. Commissioner.
Estate of Sheaffer v. Commissioner
Docket No. 4146-64.
United States Tax Court
T.C. Memo 1966-126; 1966 Tax Ct. Memo LEXIS 156; 25 T.C.M. (CCH) 646; T.C.M. (RIA) 66126;
June 10, 1966
In 1954 petitioners transferred 70,000 shares of S Corporation stock to four irrevocable trusts they created for their children. In 1955, pursuant to the trust agreement, the corporate trustee timely paid petitioners' 1954 gift tax liability out of accumulated trust income…
2Cases cited6 opinions
- Helvering v. StuartSupreme Court of the United States · 1942
- Douglas v. WillcutsSupreme Court of the United States · 1935
- Sheaffer v. CommissionerUnited States Tax Court · 1961
- Morgan v. CommissionerUnited States Tax Court · 1962
- Estate Of Craig R. SheafferCourt of Appeals for the Eighth Circuit · 1963
1 more not listed; retrieve them via the Exa API.
3Cited by2 opinions
- Hirst v. CommissionerUnited States Tax Court · 1974
- Hirst v. CommissionerUnited States Tax Court · 1974