Legal Opinion

Myer v. Commissioner

United States Tax Court

Decided January 17, 1946No. Docket No. 5085Published

Petitioner was the settlor-trustee of a trust created for the benefit of her son. As trustee she had broad managerial powers and the right to distribute or accumulate the income until the beneficiary reached the age of 30 years, at which time the accumulated income as well as the corpus of the trust was distributable to him. Held, no part of the income of the trust is taxable to petitioner under section 22 (a), Internal Revenue Code.

Read the full summary

Petitioner was the settlor-trustee of a trust created for the benefit of her son. As trustee she had broad managerial powers and the right to distribute or accumulate the income until the beneficiary reached the age of 30 years, at which time the accumulated income as well as the corpus of the trust was distributable to him. Held, no part of the income of the trust is taxable to petitioner under section 22 (a), Internal Revenue Code. J. M. Leonard, 4 T. C. 1271, and cases cited therein.

1Opinion of the Court

Alma M. Myer, Petitioner, v. Commissioner of Internal Revenue, Respondent

Myer v. Commissioner

Docket No. 5085

United States Tax Court

6 T.C. 77; 1946 U.S. Tax Ct. LEXIS 314;

January 17, 1946, Promulgated

Decision will be entered for the petitioner.

Petitioner was the settlor-trustee of a trust created for the benefit of her son. As trustee she had broad managerial powers and the right to distribute or accumulate the income until the beneficiary reached the age of 30 years, at which time the accumulated income as well as the corpus of the trust was distributable to him. Held, no part of the income…

Also in this document: Dissent.

2Cases cited10 opinions

  1. Helvering v. CliffordSupreme Court of the United States · 1940
  2. John Kelley Co. v. CommissionerSupreme Court of the United States · 1946
  3. Cartinhour v. CommissionerUnited States Tax Court · 1944
  4. Lowenstein v. CommissionerUnited States Tax Court · 1944
  5. Stockstrom v. CommissionerUnited States Tax Court · 1944

5 more not listed; retrieve them via the Exa API.

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API