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Estate of Boykin v. Commissioner
United States Tax Court
T.C.M. 1987-134 (1987)
- Written by Eric Miller, JD
Facts
John Boykin owned 7,000 shares of voting stock in Tensaw Land & Timber Company, Inc. (Tensaw). Tensaw later amended its articles of incorporation to authorize the issuance of 150,000 shares of nonvoting stock, each including a right to receive 10 times the dividends paid on the voting stock when Tensaw reached a sufficient net worth. Boykin transferred his 7,000 shares of the voting stock to an irrevocable trust for the benefit of his sons. Following Boykin’s death, the commissioner of the Internal Revenue Service (defendant) determined that Boykin had retained a right to income from the 7,000 shares. Boykin’s estate (plaintiff) challenged the determination in the United States Tax Court.
Rule of Law
Issue
Holding and Reasoning (Körner, J.)
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