Sampson v. Commissioner of Internal Revenue

BEFORE: GUY and BOGGS, Circuit Judges; and SUHRHEINRICH, District Judge.* Per Curiam. William and Lucille Sampson appeal the decision of the Tax Court holding them liable for deficiencies in personal
income tax for the years 1975 to 1979. William was a self-employed osteopath. In September 1975, he formed a professional
corporation, W. Clifford Sampson, Inc. He was the president, sole shareholder, and only employee. In April 1975, Lucille established
the "Lucille A. Sampson Pure Equity Trust" and transferred the family home to the trust. William, Lucille, and their two children
were the trustees and the only beneficiaries of the trust. The trust executed a contract, first with William personally, and
later with the corporation, whereby William agreed to render his services for the benefit of the trust in exchange for living
and working quarters.