Legal Opinion

Prouty v. Commissioner

United States Board of Tax Appeals

Decided June 28, 1934No. Docket No. 57829Published

1. Where a revocable trust so remained for a portion of the taxable year 1927 and the record does not show that the dividends or any portion thereof arising from the trust and received by the trustee in that year were received after the trust ceased to be revocable within the meaning of section 219(g) of the Revenue Act of 1926, the dividends should be included in computing the net income of the grantor for the taxable year 1927, as determined by the Commissioner. 2. A trust…

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1. Where a revocable trust so remained for a portion of the taxable year 1927 and the record does not show that the dividends or any portion thereof arising from the trust and received by the trustee in that year were received after the trust ceased to be revocable within the meaning of section 219(g) of the Revenue Act of 1926, the dividends should be included in computing the net income of the grantor for the taxable year 1927, as determined by the Commissioner. 2. A trust is not revocable within the meaning of section 219(g) of the Revenue Act of 1926 or of section 166 of the Revenue Act…

1Opinion of the Court

OLIVE H. PROUTY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Prouty v. Commissioner

Docket No. 57829.

United States Board of Tax Appeals

30 B.T.A. 1068; 1934 BTA LEXIS 1228;

June 28, 1934, Promulgated

1. Where a revocable trust so remained for a portion of the taxable year 1927 and the record does not show that the dividends or any portion thereof arising from the trust and received by the trustee in that year were received after the trust ceased to be revocable within the meaning of section 219(g) of the Revenue Act of 1926, the dividends should be included in computing the net…

2Cases cited1 opinion

  1. Prouty v. CommissionerUnited States Board of Tax Appeals · 1934

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