Porter v. Commissioner of Internal Revenue

L. HAND, Circuit Judge.

Porter, the petitioners’ testator, in 1918 and 1919, conveyed personal property to a trust company, under two deeds of trust, by which he created interests in specified beneficiaries, not necessary to set forth. Eaeh deed reserved to him a sole power to revoke the appointments and substitute other beneficiaries, expressly excepting himself and his estate. He died in November, 1926, just before his death revoking the earlier deed and substituting another of the same kind. The chief question is whether the funds so conveyed are to be included as a part of his taxable…