Richards v. Commissioner
United States Tax Court
In 1941, petitioner, who was president, director and holder of 50 per cent of the voting stock of X and Y Corporations, executed 9 separate trust instruments purporting to convey to the trustees, without reversion, "legal title in and to a beneficial interest in and to" 70 per cent of his stock in X and Y. Each of petitioners 9 children was the beneficiary of one of the trusts, which were irrevocable and to endure for the maximum period permitted by law.
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In 1941, petitioner, who was president, director and holder of 50 per cent of the voting stock of X and Y Corporations, executed 9 separate trust instruments purporting to convey to the trustees, without reversion, "legal title in and to a beneficial interest in and to" 70 per cent of his stock in X and Y. Each of petitioners 9 children was the beneficiary of one of the trusts, which were irrevocable and to endure for the maximum period permitted by law. Petitioner reserved no control over trustees or administration of the trusts, and no trust income was to be accumulated for his benefit or…
1Opinion of the Court
Loretto McKenna Richards, Petitioner, v. Commissioner of Internal Revenue, Respondent. Ernest V. Richards, Jr., Petitioner, v. Commissioner of Internal Revenue, Respondent
Richards v. Commissioner
Docket Nos. 25437, 25438
United States Tax Court
19 T.C. 366; 1952 U.S. Tax Ct. LEXIS 33;
November 28, 1952, Promulgated
Decision will be entered under Rule 50.
In 1941, petitioner, who was president, director and holder of 50 per cent of the voting stock of X and Y Corporations, executed 9 separate trust instruments purporting to convey to the trustees, without reversion, "legal title in and to a…
2Cases cited18 opinions
- Helvering v. CliffordSupreme Court of the United States · 1940
- Helvering v. HorstSupreme Court of the United States · 1940
- Blair v. CommissionerSupreme Court of the United States · 1937
- Paramount-Richards Theatres, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1946
- Green v. CommissionerUnited States Tax Court · 1946
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