Legal Opinion

Richardson v. Comm'r

United States Tax Court

Decided April 11, 2006No. Nos. 16794-03, 16795-03UnpublishedCited by 6 opinions

Ps established a tiered trust arrangement and transferred to the entities their assets, including their personal residence and lifetime services. Held: The trusts implemented and used by Ps during 1996 and 1997 should be disregarded for tax purposes as sham entities lacking in economic substance, with resultant inclusion by Ps of income reported by the trusts, recomputation of business deductions allowable to Ps, and liability for self-employment taxes.

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Ps established a tiered trust arrangement and transferred to the entities their assets, including their personal residence and lifetime services. Held: The trusts implemented and used by Ps during 1996 and 1997 should be disregarded for tax purposes as sham entities lacking in economic substance, with resultant inclusion by Ps of income reported by the trusts, recomputation of business deductions allowable to Ps, and liability for self-employment taxes. Held, further, Ps are not entitled to capital loss amounts claimed for both years and must recognize a capital gain in 1997. Held, further, P…

1Opinion of the Court

HOMER L. RICHARDSON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent GLORIA M. RICHARDSON, Petitioner v. COMMISSIONER OR INTERNAL REVENUE, Respondent

Richardson v. Comm'r

Nos. 16794-03, 16795-03

United States Tax Court

T.C. Memo 2006-69; 2006 Tax Ct. Memo LEXIS 71; 91 T.C.M. (CCH) 981;

April 11, 2006, Filed

Ps established a tiered trust arrangement and transferred to the

entities their assets, including their personal residence and

lifetime services.

Held: The trusts implemented and used by Ps during 1996

and 1997 should be disregarded for tax purposes as sham entities

lacking in economic…

2Cases cited71 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
  3. Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
  4. Gregory v. HelveringSupreme Court of the United States · 1935
  5. Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940

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3Cited by6 opinions

  1. In re WylyUnited States Bankruptcy Court, N.D. Texas · 2016
  2. Dyer v. Comm'rUnited States Tax Court · 2012
  3. Kazhukauskas v. Comm'rUnited States Tax Court · 2012
  4. Peter E. Hendrickson & Doreen M. Hendrickson v. CommissionerUnited States Tax Court · 2019
  5. Peter E. Hendrickson & Doreen M. Hendrickson v. CommissionerUnited States Tax Court · 2019

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

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