Brown v. Commissioner
United States Tax Court
In 1962, three general partners, acting individually, formed a total of 12 trusts, each with a fractional interest in the partnership assets, and all of which were identical except in grantor, beneficiary, and size of partnership interest as corpus.
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In 1962, three general partners, acting individually, formed a total of 12 trusts, each with a fractional interest in the partnership assets, and all of which were identical except in grantor, beneficiary, and size of partnership interest as corpus. Simultaneous with the creation of the trusts, the three grantors, as general partners, and the trustee, acting for all of the trusts as limited partners, formed a limited partnership with the assets of the trusts and those interests retained by the grantors. The limited partnership and the trusts were to terminate on Dec. 31, 1972, with the assets…
1Opinion of the Court
Alice F. Brown, Jeffrey N. Brown, Susan A. Brown, Ann E. Marshall Knobloch, Thomas Robert Marshall, David William Brown, David John Marshall, Pamela Sue Brown, Robert Marshall, Rebecca E. Brown, Peggy A. Brown DeClue, and Timothy Richard Brown, Petitioners 1 v. Commissioner of Internal Revenue, Respondent
Brown v. Commissioner
Docket No. 13482-78
United States Tax Court
75 T.C. 172; 1980 U.S. Tax Ct. LEXIS 35;
October 28, 1980, Filed
Decision will be entered for the petitioners.
In 1962, three general partners, acting individually, formed a total of 12 trusts, each with a fractional interest in the…
2Cases cited16 opinions
- Commissioner v. Estate of BoschSupreme Court of the United States · 1967
- Commissioner of Internal Revenue v. Goodwyn Crockery CompanyCourt of Appeals for the Sixth Circuit · 1963
- Young v. BradleySupreme Court of the United States · 1880
- Garth v. CommissionerUnited States Tax Court · 1971
- Goodwyn Crockery Co. v. CommissionerUnited States Tax Court · 1961
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