Katz v. Commissioner
United States Board of Tax Appeals
Held, that the income of three trusts as to which the petitioner was the grantor and trustee is not taxable to him under section 22(a), section 166, or section 167, of the Revenue Acts of 1936 and 1938.
1Opinion of the Court
*193OPINION.
Tyson:
The pleadings raise two issues involving the questions of whether the income of the three trusts for the benefit of petitioner’s children is taxable to petitioner (1) under the broad provisions of section 22 (a) of the Kevenue Acts of 1936 and 1938,1 because, in substance, he retained ownership of the trust property, or, (2) under the specific provisions of section 166 of those acts2 because he reserved a power of revocation of the trusts.
Under Helvering v. Clifford, 309 U. S. 331, the applicability of section 22 (a), supra, depends upon whether, after creating the trusts the…
2Cases cited1 opinion
- Helvering v. CliffordSupreme Court of the United States · 1940
3Cited by6 opinions
- Bodell v. CommissionerUnited States Tax Court · 1943
- Cullen v. CommissionerUnited States Tax Court · 1944
- Edison v. CommissionerUnited States Tax Court · 1944
- Katz v. CommissionerUnited States Board of Tax Appeals · 1942
- Nathan v. CommissionerUnited States Tax Court · 1943
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