Tiberti v. Commissioner
United States Tax Court
Petitioner J. A. Tiberti owned and operated as a sole proprietorship a general construction business. He and his wife created four trusts for their minor children, to each of which one-fifth of the assets of the business was contributed. A partnership was created, with Tiberti as the managing partner and two contrustees as partners representing the four trusts. All of the business assets were contributed to this partnership.
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Petitioner J. A. Tiberti owned and operated as a sole proprietorship a general construction business. He and his wife created four trusts for their minor children, to each of which one-fifth of the assets of the business was contributed. A partnership was created, with Tiberti as the managing partner and two contrustees as partners representing the four trusts. All of the business assets were contributed to this partnership. Held, the transfers in trust were bona fide and each of the trusts owned a one-fifth capital interest in a bona fide partnership in which capital was a material…
1Opinion of the Court
Jelindo A. Tiberti and Marietta Tiberti v. Commissioner.
Tiberti v. Commissioner
Docket No. 89138.
United States Tax Court
T.C. Memo 1962-174; 1962 Tax Ct. Memo LEXIS 133; 21 T.C.M. (CCH) 961; T.C.M. (RIA) 62174;
July 25, 1962
Petitioner J. A. Tiberti owned and operated as a sole proprietorship a general construction business. He and his wife created four trusts for their minor children, to each of which one-fifth of the assets of the business was contributed. A partnership was created, with Tiberti as the managing partner and two contrustees as partners representing the four trusts. All of the…
2Cases cited5 opinions
- Blair v. CommissionerSupreme Court of the United States · 1937
- Stern v. CommissionerUnited States Tax Court · 1950
- Reddig v. CommissionerUnited States Tax Court · 1958
- Smith v. CommissionerUnited States Tax Court · 1959
- Walberg v. SmythDistrict Court, N.D. California · 1956
3Cited by2 opinions
- Tifd Iii-E, Inc. v. United StatesCourt of Appeals for the Second Circuit · 2012
- Ginsberg v. CommissionerUnited States Tax Court · 1973