STRIMLING v. C.I.R.

CA No. 83-7617.

734 F.2d 1377 (1984)

Murton D. STRIMLING and Brenda Strimling, Frank S. Cavallaro and Diana Cavallaro, Steven C. Kalb and Wendy A. Kalb, Erven J. Nelson and Marion T. Nelson, Richard B. Scarff, Jr. and Jeanne Scarff, John Robarts and Ann Robarts, Patrick M. Flanagan and Grace Flanagan, Remo Bedotto and Esther Z. Bedotto, Albert C. Merkin and Eunice Merkin, Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, Ninth Circuit.

Decided June 8, 1984.


Attorney(s) appearing for the Case

Bruce I. Hochman, Hochman, Salkin & DeRoy, Beverly Hills, Cal., for appellants.

Ernest J. Brown, Washington, D.C., for appellee.

Before WALLACE, KENNEDY and CANBY, Circuit Judges:


PER CURIAM.

This appeal arises from the attempts of several taxpayers to establish "Clifford Trusts" for the benefit of their children. See 26 U.S.C. §§ 671-78 (1976). In each case the corpus of the trust consisted of $10 cash and a promissory note executed by taxpayers in amounts ranging from $10,000 to $85,000. Taxpayers made payments to the trusts of "interest" on the notes and sought interest deductions therefor.

The Tax Court, in a well...

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