Legal Opinion

Madorin v. Commissioner

United States Tax Court

Decided April 11, 1985No. Docket No. 28963-81Published

Petitioner was the grantor of four trusts. Because the trustee of the trusts had the power to add beneficiaries, the trusts were grantor trusts pursuant to sec. 674(a), I.R.C. 1954. The trusts purchased limited partnership interests in Metro, which in turn purchased a limited partnership interest in Saintly. Petitioner, as grantor, recognized on his joint income tax return the losses generated by Saintly.

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Petitioner was the grantor of four trusts. Because the trustee of the trusts had the power to add beneficiaries, the trusts were grantor trusts pursuant to sec. 674(a), I.R.C. 1954. The trusts purchased limited partnership interests in Metro, which in turn purchased a limited partnership interest in Saintly. Petitioner, as grantor, recognized on his joint income tax return the losses generated by Saintly. At the point Saintly began generating income, the trustee renounced his power to add beneficiaries, and the trusts ceased to be grantor trusts, i.e., they were perfected. Held, sec.…

1Opinion of the Court

Bernard and Joyce Madorin, Petitioners v. Commissioner of Internal Revenue, Respondent

Madorin v. Commissioner

Docket No. 28963-81

United States Tax Court

84 T.C. 667; 1985 U.S. Tax Ct. LEXIS 94; 84 T.C. No. 44;

April 11, 1985. April 11, 1985, Filed

Petitioner was the grantor of four trusts. Because the trustee of the trusts had the power to add beneficiaries, the trusts were grantor trusts pursuant to sec. 674(a), I.R.C. 1954. The trusts purchased limited partnership interests in Metro, which in turn purchased a limited partnership interest in Saintly. Petitioner, as grantor, recognized on his…

2Cases cited30 opinions

  1. Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
  2. Old Colony Trust Co. v. CommissionerSupreme Court of the United States · 1929
  3. Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
  4. Crane v. CommissionerSupreme Court of the United States · 1947
  5. United States v. CorrellSupreme Court of the United States · 1967

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