Metzger Trust v. Commissioner
United States Tax Court
A brother and two sisters were shareholders in MDI and remaindermen in a trust which also held stock in MDI. Family hostility among the siblings caused MDI to redeem the stock owned by the trust and the two sisters. The trust was included in the redemption because under its terms, the stock it held in MDI would have passed to the remaindermen who were attempting to separate their business and family relations.
Read the full summary
A brother and two sisters were shareholders in MDI and remaindermen in a trust which also held stock in MDI. Family hostility among the siblings caused MDI to redeem the stock owned by the trust and the two sisters. The trust was included in the redemption because under its terms, the stock it held in MDI would have passed to the remaindermen who were attempting to separate their business and family relations. The trust complied with the prerequisites of sec. 302(c)(2)(A), I.R.C. 1954, and filed an agreement purporting to waive the trust-beneficiary attribution rules of sec. 318(a)(3). In…
1Opinion of the Court
David Metzger Trust, Jacob Metzger, Trustee, Petitioner v. Commissioner of Internal Revenue, Respondent; Metzger Dairies, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent
Metzger Trust v. Commissioner
Docket Nos. 8824-77, 8856-77, 6990-79
United States Tax Court
76 T.C. 42; 1981 U.S. Tax Ct. LEXIS 192;
January 12, 1981, Filed
Decisions will be entered in all dockets under Rule 155.
A brother and two sisters were shareholders in MDI and remaindermen in a trust which also held stock in MDI. Family hostility among the siblings caused MDI to redeem the stock owned by the trust and the…
Also in this document: Concurrence.
2Cases cited55 opinions
- Tennessee Valley Authority v. HillSupreme Court of the United States · 1978
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Mobil Oil Corp. v. HigginbothamSupreme Court of the United States · 1978
- United States v. CalamaroSupreme Court of the United States · 1957
- United States v. DavisSupreme Court of the United States · 1970
50 more not listed; retrieve them via the Exa API.