Morton v. Commissioner
United States Board of Tax Appeals
1. Petitioner created three trusts in each of which the trustee had the right to terminate the trust and revest the corpus in the grantor.
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1. Petitioner created three trusts in each of which the trustee had the right to terminate the trust and revest the corpus in the grantor. Held, the trusts are revocable and income thereof is taxable to petitioner, since trustee is not a person having a substantial adverse interest. 2. To one of these trusts created by him, petitioner assigned all of his interest under a certain trust created by his father, Joy Morton, one-third of the income of which was payable to petitioner. The income of this trust created by petitioner was to be accumulated. Under the terms of the Joy Morton trust,…
1Opinion of the Court
OPINION.
Kern:
This proceeding involves that part of a deficiency in the sum of $18,190.45 determined by respondent in petitioner’s income tax liability for the year 1933 arising by reason of (1) respondent’s, disallowance of a deduction claimed by petitioner in the sum of $796.94 representing interest paid by him on an obligation of the 1260 Astor Street Building Syndicate, (2) respondent’s disallowance of a deduction claimed by petitioner on the ground that his investment in the 1242 Lake Shore Drive Syndicate became worthless in the taxable year, and (3) respondent’s inclusion in…
2Cases cited4 opinions
- Corliss v. BowersSupreme Court of the United States · 1930
- Blair v. CommissionerSupreme Court of the United States · 1937
- Porter v. CommissionerSupreme Court of the United States · 1933
- Reinecke v. SmithSupreme Court of the United States · 1933
3Cited by4 opinions
- Frease v. CommissionerUnited States Tax Court · 1944
- Mills v. CommissionerUnited States Board of Tax Appeals · 1939
- Morton v. CommissionerUnited States Board of Tax Appeals · 1938
- Sharp v. CommissionerUnited States Board of Tax Appeals · 1940