Benson v. Commissioner
United States Tax Court
Petitioners purportedly transferred to a family trust most of their business and personal assets, including their home, petitioner-husband's office equipment, and their lifetime personal services and all remuneration therefrom. Petitioners continued to use their home and personal assets, and petitioner-husband continued to use his office equipment in his accounting practice.
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Petitioners purportedly transferred to a family trust most of their business and personal assets, including their home, petitioner-husband's office equipment, and their lifetime personal services and all remuneration therefrom. Petitioners continued to use their home and personal assets, and petitioner-husband continued to use his office equipment in his accounting practice. Held: (1) The trust was devoid of economic reality and is not recognizable for Federal income tax purposes. (2) In docket No. 28467-81, petitioners are liable for additions to tax under section 6653(a), I.R.C. 1954. (3)…
1Opinion of the Court
RAYMOND S. BENSON and BARBARA G. BENSON, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Benson v. Commissioner
Docket Nos. 14177-78, 28467-81.
United States Tax Court
T.C. Memo 1983-458; 1983 Tax Ct. Memo LEXIS 332; 46 T.C.M. (CCH) 955; T.C.M. (RIA) 83458;
August 4, 1983
Petitioners purportedly transferred to a family trust most of their business and personal assets, including their home, petitioner-husband's office equipment, and their lifetime personal services and all remuneration therefrom. Petitioners continued to use their home and personal assets, and petitioner-husband…
2Cases cited9 opinions
- Luman v. CommissionerUnited States Tax Court · 1982
- Wallace J. Vnuk and Frances R. Vnuk v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1980
- Markosian v. CommissionerUnited States Tax Court · 1980
- Vercio v. CommissionerUnited States Tax Court · 1980
- Wesenberg v. CommissionerUnited States Tax Court · 1978
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