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. Backgrounda In the mid 1960s, Edward owned a one-third interest in National Amusement, Inc. ("NAI") along with his brother, Sumner, and his dad, Mickey. Later, Mickey exchanged his interest for preferred stock and gave a 20% voting interest to the Grandchidren's Trust. This left Edward and Sumner w
the case of Edward Redstone v. Commissioned. While the Tax Court agreed with Edward, it disagreed in a later decision involving Edward's brother, Sumner - arguments about similar facts, but with a haunting twist of beyond the grave revenge. Backgrounda In the mid 1960s, Edward owned a one-third int
EFTA00668065 However, at Sumner's trial, the Tax Court stated, There is no evidence that any dispute existed in 1971-1972 concerning ownership of Sumner's stock or that Mickey was determined to withhold any of Sumner's shares from him. To the contrary: the evidence showed that Mickey and Sumner were
's trusts as a result of the oral agreement. In other words, the math didn't work. The differential between the 48 percent of assets contributed by Mickey and the one-third of the stock he received was supposed to go the grandchildren under the "oral trust" argument esposed by Mickey. If there was an "
, There is no evidence that any dispute existed in 1971-1972 concerning ownership of Sumnees stock or that Mickey was determined to withhold any of Sumner's shares from him. To the contrary: the evidence showed that Mickey and Sumner were working in concert to drive Edward out of the company and that
ior Court and the Court "issued a Final Decree incorporating the terms of the Settlement Agreement." Three weeks after the Final Decree was issued, Sumner, in support of his father's wishes, "executed irrevocable declarations of trust for the benefit of his two children" and transferred a similar amoun
. Background' In the mid 1960s, Edward owned a one-third interest in National Amusement, Inc. ("NAI") along with his brother, Sumner, and his dad, Mickey. Later, Mickey exchanged his interest for preferred stock and gave a 20% voting interest to the Grandchidren's Trust. This left Edward and Sumner wi
he case of Edward Redstone v. Commissionerill. While the Tax Court agreed with Edward, it disagreed in a later decision involving Edward's brother, Sumner - arguments about similar facts, but with a haunting twist of beyond the grave revenge. Background' In the mid 1960s, Edward owned a one-third int
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