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IN RE RICHARDS

No. Civ.A. 98-5148, Bankruptcy No. 97-14798DWS.

231 B.R. 571 (1999)

In re Eugene T. RICHARDS, Jr. and Mary Ellen B. Richards, Debtors. Mark Burke Richards, Intervenor-Appellant, v. United States of America, Appellee.

United States District Court, E.D. Pennsylvania, Philadelphia Division.

January 29, 1999.

Attorney(s) appearing for the Case

Mark L. Tunnell, Gawthrop, Greenwood and Halsted, West Chester, PA, John R. Crayton, Crayton and Belknap, Bensalem, PA, for Mary Ellen B. Richards, debtor.

John R. Crayton, Crayton and Belknap, Bensalem, PA,, for Eugene T. Richards, debtor.

Roger N. Huggins, Gawthrop, Greenwood and Halsted, West Chester, PA, for Mark Burke Richards, intervenor-appellant.

Charles M. Flesch, Tax Division of U.S. Dept of Justice, Washington, DC, for United States, U.S. Dept. of Justice, Tax Div., appellee.

Edward Sparkman, Philadelphia, PA, trustee pro se.

OPINION

BUCKWALTER, District Judge.

I. INTRODUCTION

After a trial on the merits, the United States Bankruptcy Court for the Eastern District of Pennsylvania held that the debtors' trust, the corpus of which is real property, is their nominee as co-trustees for the benefit of their minor son, even though it had previously found that the trust was validly created and not a sham, and that the conveyance of the property to the trust was not...

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