Burroughs Corp. v. Commissioner
United States Tax Court
1. Under date of December 21, 1953, the petitioner, as settlor, and two individuals, as trustees, executed a trust indenture creating Burroughs Foundation Auxiliary Trust with the trust res consisting of Burroughs Farms, which is a tract of approximately 585 acres of land acquired by petitioner in 1926 or 1927 to provide a recreational area and facilities for its employees and their families.
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1. Under date of December 21, 1953, the petitioner, as settlor, and two individuals, as trustees, executed a trust indenture creating Burroughs Foundation Auxiliary Trust with the trust res consisting of Burroughs Farms, which is a tract of approximately 585 acres of land acquired by petitioner in 1926 or 1927 to provide a recreational area and facilities for its employees and their families. Continuously, since 1927 Burroughs Farms has been used for such purpose and it has the reputation of being one of the best recreational centers in Michigan. On December 21, 1953, the petitioner executed…
1Opinion of the Court
Withey, Judge:
The respondent has determined a deficiency of $301,672.68 in the income tax of the petitioner for 1953. The only issues presented by the pleadings and not disposed of by stipulation of the parties are the correctness of the respondent’s action in determining (1) that petitioner was not entitled under the provisions of section 23 (o) and (q) of the Internal Revenue Code of 1939 to deduct any amount as a contribution on account of petitioner’s conveyance in 1953 of certain real estate to Burroughs Foundation Auxiliary Trust, (2) that the petitioner was not entitled under the…
2Cases cited5 opinions
- Estate of Sanford v. CommissionerSupreme Court of the United States · 1939
- Burnet v. GuggenheimSupreme Court of the United States · 1933
- Smith v. ShaughnessySupreme Court of the United States · 1943
- Fair v. CommissionerUnited States Tax Court · 1957
- Colorado Nat'l Bank v. CommissionerUnited States Tax Court · 1958
3Cited by11 opinions
- Oakes v. Comm'rUnited States Tax Court · 1965
- Christensen v. CommissionerUnited States Tax Court · 1963
- Londen v. CommissionerUnited States Tax Court · 1965
- Darling v. CommissionerUnited States Tax Court · 1965
- Burroughs Corp. v. CommissionerUnited States Tax Court · 1959
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