Legal Opinion

Woolley v. Commissioner

United States Board of Tax Appeals

Decided April 21, 1939No. Docket No. 87285Published

On February 10, 1933, the taxpayer created a revocable trust for the life of the settlor, the income of which was payable in such proportions as his wife, trustee, determined in her discretion or to be accumulated, in her discretion, for distribution, before or at the termination of the trust, to a beneficiary other than the taxpayer.

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On February 10, 1933, the taxpayer created a revocable trust for the life of the settlor, the income of which was payable in such proportions as his wife, trustee, determined in her discretion or to be accumulated, in her discretion, for distribution, before or at the termination of the trust, to a beneficiary other than the taxpayer. On June 19, 1934, the taxpayer wrote the trustee revoking the trust, and of said trust as of January 1, 1937. pursuant to a contract with the trustee for a consideration of $100, taxpayer wrote to the trustee, relinquishing any further right to revoke the trust.…

1Opinion of the Court

DANIEL P. WOOLLEY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Woolley v. Commissioner

Docket No. 87285.

United States Board of Tax Appeals

39 B.T.A. 802; 1939 BTA LEXIS 974;

April 21, 1939, Promulgated

On February 10, 1933, the taxpayer created a revocable trust for the life of the settlor, the income of which was payable in such proportions as his wife, trustee, determined in her discretion or to be accumulated, in her discretion, for distribution, before or at the termination of the trust, to a beneficiary other than the taxpayer. On June 19, 1934, the taxpayer wrote the trustee…

2Cases cited10 opinions

  1. Rovensky v. CommissionerUnited States Board of Tax Appeals · 1938
  2. Downs v. CommissionerUnited States Board of Tax Appeals · 1937
  3. Dunning v. CommissionerUnited States Board of Tax Appeals · 1937
  4. Wood v. CommissionerUnited States Board of Tax Appeals · 1938
  5. Shiverick v. CommissionerUnited States Board of Tax Appeals · 1938

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