Legal Opinion

Paxton v. Commissioner

United States Tax Court

Decided February 15, 1972No. Docket No. 6091-70PublishedCited by 17 opinions

In 1967 petitioners established the F. G. Paxton Family Organization (a Trust). Petitioners, their two sons and daughters-in-law, and an employee of KLC contributed their stock in KLC to the trust in exchange for certificates of beneficial interest in the trust. Petitioners also contributed their house, furniture, and other property as trust assets.

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In 1967 petitioners established the F. G. Paxton Family Organization (a Trust). Petitioners, their two sons and daughters-in-law, and an employee of KLC contributed their stock in KLC to the trust in exchange for certificates of beneficial interest in the trust. Petitioners also contributed their house, furniture, and other property as trust assets. Petitioners received an 86.38-percent interest in the trust, J and N Paxton each received a 3.84-percent interest, T and S Paxton each received a 2.59-percent interest, and the employee PC and his wife each received a 0.38-percent interest. The…

1Opinion of the Court

OPINION

Dawson, Judge:

Bespondent determined a deficiency of $3,987.92 in petitioners’ Federal income tax for the year 1967.

The parties have made certain concessions which can be given effect in the Buie 50 computation. The primary issue for decision is whether the F. G. Paxton Family Organization (a Trust) is a grantor trust under sections 671 through 677, I.B.C. 1954,1 the income from which in 1967 is 86.38 percent taxable to petitioners, or whether it is a complex trust, the income from which is not taxable to petitioners. Alternatively, if the F. G. Paxton Family Organization (a Trust) is…

2Cases cited10 opinions

  1. Athanasius Y. Samuel v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1962
  2. De Amodio v. CommissionerUnited States Tax Court · 1960
  3. Humphrey v. CommissionerUnited States Tax Court · 1962
  4. Inez De Amodio, in No. 13740, John Amodio (Marquis Deamodio), in No. 13741 v. Commissioner of Internatal RevenueCourt of Appeals for the Third Circuit · 1962
  5. Archbishop Samuel Trust v. CommissionerUnited States Tax Court · 1961

5 more not listed; retrieve them via the Exa API.

3Cited by17 opinions

  1. Vercio v. CommissionerUnited States Tax Court · 1980
  2. United States v. Staniford A. SorrentinoCourt of Appeals for the First Circuit · 1984
  3. Estate of Paxton v. CommissionerUnited States Tax Court · 1986
  4. Floyd G. Paxton and Grace D. Paxton v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1975
  5. Estate of Paxton v. CommissionerUnited States Tax Court · 1982

12 more not listed; retrieve them via the Exa API.

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