Legal Opinion

Willson v. Commissioner

United States Board of Tax Appeals

Decided May 27, 1941No. Docket No. 99980Published

1. Where a woman created a trust and irrevocably assigned to it certain insurance policies taken out on the life of her husband and also transferred certain securities to the trust with directions to use the income therefrom to pay the premiums on the policies of insurance and to accumulate the balance of the income, if any, and add it to the corpus of the trust, held, the income used to pay the premiums on the insurance policies is not taxable to her.

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1. Where a woman created a trust and irrevocably assigned to it certain insurance policies taken out on the life of her husband and also transferred certain securities to the trust with directions to use the income therefrom to pay the premiums on the policies of insurance and to accumulate the balance of the income, if any, and add it to the corpus of the trust, held, the income used to pay the premiums on the insurance policies is not taxable to her. Lucy A. Blumenthal,30 B.T.A. 591, followed. 2. Where the trust indenture mentioned above provided that the income not used to pay insurance…

1Opinion of the Court

FRANCES S. WILLSON, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Willson v. Commissioner

Docket No. 99980.

United States Board of Tax Appeals

44 B.T.A. 583; 1941 BTA LEXIS 1307;

May 27, 1941, Promulgated

1. Where a woman created a trust and irrevocably assigned to it certain insurance policies taken out on the life of her husband and also transferred certain securities to the trust with directions to use the income therefrom to pay the premiums on the policies of insurance and to accumulate the balance of the income, if any, and add it to the corpus of the trust, held, the income…

2Cases cited6 opinions

  1. Helvering v. HorstSupreme Court of the United States · 1940
  2. Corliss v. BowersSupreme Court of the United States · 1930
  3. Douglas v. WillcutsSupreme Court of the United States · 1935
  4. Blumenthal v. CommissionerUnited States Board of Tax Appeals · 1934
  5. Dravo v. CommissionerUnited States Board of Tax Appeals · 1936

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