Gordon v. Commissioner
United States Tax Court
Petitioner husband and petitioner wife, the latter as trustee of a trust established by petitioner husband for the benefit of petitioners' children, entered into joint purchase agreements whereby, in form, petitioner husband purchased income interests for life, and the trust purchased remainder interests, in certain bonds. Petitioner husband entered into a similar agreement with himself as trustee of a pension trust for the benefit of his employees.
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Petitioner husband and petitioner wife, the latter as trustee of a trust established by petitioner husband for the benefit of petitioners' children, entered into joint purchase agreements whereby, in form, petitioner husband purchased income interests for life, and the trust purchased remainder interests, in certain bonds. Petitioner husband entered into a similar agreement with himself as trustee of a pension trust for the benefit of his employees. Held, because, in substance, petitioner husband purchased the bonds in their entirety, petitioners' amortization deductions for the cost of the…
1Opinion of the Court
Tannenwald, Judge:
Respondent determined deficiencies in petitioners’ Federal income taxes for taxable years 1976, 1977, and 1978 of $4,852, $7,903, and $17,296.50, respectively. After concessions by both parties concerning petitioners’ distributive share of certain partnership losses, the sole issue for decision is whether respondent properly denied petitioners’ amortization deductions with respect to the purported acquisition by petitioner Everett J. Gordon (Dr. Gordon) of income interests in municipal bonds purchased pursuant to joint purchase agreements entered into by Dr. Gordon and…
2Cases cited43 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Helvering v. CliffordSupreme Court of the United States · 1940
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Griffiths v. CommissionerSupreme Court of the United States · 1939
- Professional Services v. CommissionerUnited States Tax Court · 1982
38 more not listed; retrieve them via the Exa API.
3Cited by28 opinions
- 508 Clinton St. Corp. v. CommissionerUnited States Tax Court · 1987
- Cooper v. CommissionerUnited States Tax Court · 1987
- John Michael Wheeler, Independent of the Estate of Elmore K. Melton, Jr. v. United StatesCourt of Appeals for the Fifth Circuit · 1997
- Kornfeld v. CommissionerCourt of Appeals for the Tenth Circuit · 1998
- Superior Trading, LLC v. Comm'rUnited States Tax Court · 2011
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