Succession of Harrison v. United States

ALVIN B. RUBIN, District Judge:

Prior to April 14, 1960, the plaintiffs 1 owned certain oil properties in Louisiana. On that date they incorporated the Harrison Property Management Co., Inc., and made a simulated transfer of the properties to the corporation. A counter letter was reserved expressing the true intention of the parties, that is, that the corporation did not have “any right, title or interest in and to said Property other than the right to manage and administer said P'roperty. .” The counter letter also contained a provision stating that all expenses incurred by the corporation in…