Legal Opinion

Burroughs Corp. v. Commissioner

United States Tax Court

Decided November 30, 1959No. Docket No. 72023Published

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

Burroughs Corporation, Petitioner, v. Commissioner of Internal Revenue, Respondent

Burroughs Corp. v. Commissioner

Docket No. 72023

United States Tax Court

33 T.C. 389; 1959 U.S. Tax Ct. LEXIS 26;

November 30, 1959, Filed

Decision will be entered under Rule 50.

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…

2Cases cited6 opinions

  1. Estate of Sanford v. CommissionerSupreme Court of the United States · 1939
  2. Burnet v. GuggenheimSupreme Court of the United States · 1933
  3. Smith v. ShaughnessySupreme Court of the United States · 1943
  4. Fair v. CommissionerUnited States Tax Court · 1957
  5. Colorado Nat'l Bank v. CommissionerUnited States Tax Court · 1958

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