Madeira v. Commissioner

DICKINSON, District Judge.

The fact situation may be easily presented. The petitioner was the owner of 1500 shares of stock of Madeira, Hill & Company. He wished to retire from its management and activities. He had been associated with the Company for many years and younger members of his family were ready to take his place. It was natural that he should not wish the ownership of the stock to pass to strangers. He likewise wished to make a trust provision for his children in which the stock of the Company would form the corpus of the trust. The stock had depreciated in value since 1913. It at…