Coates Trust v. Commissioner
United States Tax Court
The Coates family owned all of the shares of CAM corporation and WIP corporation. CAM "purchased" the shares of WIP. Held: 1. The Rose Ann Coates Trust, not Rose Ann Coates, was the proper taxpayer where Rose Ann Coates had agreed by mutual will to place her community shares in trust, and the transaction occurred after the death of her husband. 2. The Trust Under Will of Sydney Coates was a proper taxpayer where income from a transaction executed by the Estate of Sydney…
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The Coates family owned all of the shares of CAM corporation and WIP corporation. CAM "purchased" the shares of WIP. Held: 1. The Rose Ann Coates Trust, not Rose Ann Coates, was the proper taxpayer where Rose Ann Coates had agreed by mutual will to place her community shares in trust, and the transaction occurred after the death of her husband. 2. The Trust Under Will of Sydney Coates was a proper taxpayer where income from a transaction executed by the Estate of Sydney Coates was passed through to the trust-beneficiary. 3. The transaction was a redemption by a related corporation under sec.…
1Opinion of the Court
Dawson, Judge:
In these consolidated oases respondent determined the following deficiencies in petitioners’ Federal income taxes for the year 1965:
Petitioner Docket No. Deficiency
Rose Ann Coates Trust, Robert N. Coates, Trustee_ 5810-68 $12, 936. 62
Trust Under Will of Sydney N. Coates, Robert N. Coates, Trustee_ 5813-68 5, 313. 41
Peter M. Coates- 5834r-68 654. 42
Charles N. Coates_ 5870-68 427. 00
Pamela L. Coates_ 5871-68 427. 00
Cathy A. Coates_ 5872-68 602. 87
By amendment to his answer, respondent has claimed the following additional deficiencies:
Petitioner Docket No. Deficiency
Rose Ann Coates…
2Cases cited11 opinions
- United States v. DavisSupreme Court of the United States · 1970
- Lewis v. CommissionerUnited States Tax Court · 1966
- Commissioner of Internal Revenue v. John M. Stickney, of the Estate of Henry McK Haserot, and Bonnie C. HaserotCourt of Appeals for the Sixth Circuit · 1968
- Haserot v. CommissionerUnited States Tax Court · 1966
- Allen v. DillardWashington Supreme Court · 1942
6 more not listed; retrieve them via the Exa API.
3Cited by27 opinions
- Benjamin v. CommissionerUnited States Tax Court · 1976
- Smith v. CommissionerUnited States Tax Court · 1978
- Fehrs Finance Co. v. CommissionerUnited States Tax Court · 1972
- Rose Ann Coates Trust, Appellants-Petitioners v. Commissioner of Internal Revenue, Appellee-RespondentCourt of Appeals for the Ninth Circuit · 1973
- Gunther v. CommissionerUnited States Tax Court · 1989
22 more not listed; retrieve them via the Exa API.