On June 2, 2020, the Tax Court issued its opinion in Sage v. Commissioner (154 T.C. No. 12). The issue presented in Sage v. Commissioner was whether the petitioner, who wholly owned an S corporation and LLC, which in turn owned (indirectly) and transferred three encumbered properties to separate liquidating trusts that disposed of the parcels with the profits going to pay off the liabilities of the S corporation and LLC, was the owner/grantor of the liquidating trusts pursuant to the grantor trust provisions of IRC §§ 671-679. Background to Sage v. Commissioner Petitioner, one Mr. Jason B. Sage (a distant cousin of Johnny B. Goode), found himself deeply underwater with respect to three parcels of Oregon real property, which Mr. Sage indirectly owned through wholly owned companies. He named his primary company Integrity Development Group, Inc. (Integrity), because he thought it would instill confidence in those who dealt with…