O'Reilly v. Commissioner
United States Tax Court
Ps placed stock of their closely held corporation in trusts for a period of years and retained the right to the income for the duration of the trusts. Upon the termination of the trusts, the principal was to be delivered to the remainder donees, Ps' children. Historically, the stock had paid a small dividend. Held, table B, sec. 25.2512-5(f), Gift Tax Regs., should be used to determine the value of Ps' gifts.
1Opinion of the Court
Charles H. O'Reilly, Sr., Petitioner v. Commissioner of Internal Revenue, Respondent; Alma M. O'Reilly, Petitioner v. Commissioner of Internal Revenue, Respondent
O'Reilly v. Commissioner
Docket Nos. 16353-89, 16354-89
United States Tax Court
95 T.C. 646; 1990 U.S. Tax Ct. LEXIS 116; 95 T.C. No. 46;
December 26, 1990, Filed
Decisions will be entered for the petitioners.
Ps placed stock of their closely held corporation in trusts for a period of years and retained the right to the income for the duration of the trusts. Upon the termination of the trusts, the principal was to be delivered to the…
2Cases cited17 opinions
- Weller v. CommissionerUnited States Tax Court · 1962
- McMurtry v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1953
- Fred A. Berzon v. Commissioner of Internal Revenue, Gertrude Berzon v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1976
- Berzon v. CommissionerUnited States Tax Court · 1975
- Green v. CommissionerUnited States Tax Court · 1954
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