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BUELOW v. C.I.R.

No. 90-3839.

970 F.2d 412 (1992)

Ralph C. BUELOW, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Seventh Circuit.

Decided August 12, 1992.

Attorney(s) appearing for the Case

Robert A. Adman (argued), Appleton, Wis., for petitioner-appellant.

Abraham N.M. Shashy, Jr., I.R.S., Richard Farber, Gary R. Allen, Deborah Swann, Sara Ann Ketchum (argued), Dept. of Justice, Tax Div., Appellate Section, Charles S. Casazza, U.S. Tax Court, Washington, D.C., for respondent-appellee.

Before CUDAHY and KANNE, Circuit Judges, and ESCHBACH, Senior Circuit Judge.

KANNE, Circuit Judge.

From 1979 to 1983, Ralph Buelow and his family lived on a dairy farm which he owned and operated in Chilton, Wisconsin. His daughter, Bonnie Casper, and her husband lived in another building on the farm. On June 1, 1980, Mr. Buelow executed a "Declaration of Trust," which purported to create the "Buelow Farms Trust" (trust). Mr. Buelow's wife, Carol Buelow, and Bonnie Casper were named as trustees. The declaration did not identify the beneficiaries...

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