Goodan v. Commissioner
United States Tax Court
In 1935 8 individuals transferred individually owned stock in two corporations in trust and directed the trustees to pay their pro rata share of trust income to themselves for life, then to their respective spouses, then to their issue, and then to their heirs until termination of the trust, at which time the trust corpus was to go to their issue, if any, and then to their heirs at law.
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In 1935 8 individuals transferred individually owned stock in two corporations in trust and directed the trustees to pay their pro rata share of trust income to themselves for life, then to their respective spouses, then to their issue, and then to their heirs until termination of the trust, at which time the trust corpus was to go to their issue, if any, and then to their heirs at law. The trust was to terminate upon the death of the survivor of 21 named individuals ranging in age from 68 years to 2 months and including the 8 trustors. Each trustor reserved a power of appointment of his…
1Opinion of the Court
OPINION.
ARNOLD, Judge-.
These consolidated cases involve income tax deficiencies as follows:
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The parties stipulated that there is no penalty liability under section 293 (a), Revenue Act of 1938, for the taxable year 1938 in Docket No. 3037.
Numerous issues have been settled by the parties, with the result that a single issue, common to each case for each taxable year, remains for "decision, namely, whether certain taxable stock dividends received by a trust are taxable to the trust or to its grantors, seven of whom are petitioners herein.
The parties have stipulated the amount of…
2Cases cited5 opinions
- Helvering v. CliffordSupreme Court of the United States · 1940
- Helvering v. HorstSupreme Court of the United States · 1940
- Gray v. Union Trust Co.California Supreme Court · 1915
- McColgan v. Magee, Inc.California Supreme Court · 1916
- Biddle v. CommissionerUnited States Tax Court · 1948
3Cited by8 opinions
- Druker v. CommissionerUnited States Tax Court · 1981
- Commissioner of Internal Revenue v. Goodan, and Six Other CasesCourt of Appeals for the Ninth Circuit · 1952
- Solomon v. CommissionerUnited States Tax Court · 1956
- Commissioner of Internal Revenue v. Goodan, and Six Other CasesCourt of Appeals for the Ninth Circuit · 1952
- Estate of Solomon v. CommissionerUnited States Tax Court · 1956
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