Green v. Commissioner
United States Tax Court
1. Petitioner created two trusts for the benefit of his wife and minor son, respectively. As settlor-trustee, petitioner retained broad managerial powers over the trusts, including the right to deal with himself as an individual with respect to the trust properties. Held, the petitioner is taxable as an individual on the income of the trusts under section 22 (a), Revenue Acts of 1936 and 1938 and the Internal Revenue Code. Ellis H. Warren, 45 B. T. A. 379; affd., 133 Fed.
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1. Petitioner created two trusts for the benefit of his wife and minor son, respectively. As settlor-trustee, petitioner retained broad managerial powers over the trusts, including the right to deal with himself as an individual with respect to the trust properties. Held, the petitioner is taxable as an individual on the income of the trusts under section 22 (a), Revenue Acts of 1936 and 1938 and the Internal Revenue Code. Ellis H. Warren, 45 B. T. A. 379; affd., 133 Fed. (2d) 312, followed. 2. Held, section 275 (c) of the Revenue Act of 1936 is applicable and deficiencies determined for 1937…
1Opinion of the Court
Leslie H. Green, Petitioner, v. Commissioner of Internal Revenue, Respondent
Green v. Commissioner
Docket Nos. 1780, 2570
United States Tax Court
7 T.C. 263; 1946 U.S. Tax Ct. LEXIS 134;
June 28, 1946, Promulgated
Decisions will be entered under Rule 50.
1. Petitioner created two trusts for the benefit of his wife and minor son, respectively. As settlor-trustee, petitioner retained broad managerial powers over the trusts, including the right to deal with himself as an individual with respect to the trust properties. Held, the petitioner is taxable as an individual on the income of the trusts under…
2Cases cited7 opinions
- Blair v. CommissionerSupreme Court of the United States · 1937
- Freuler v. HelveringSupreme Court of the United States · 1934
- Commissioner v. Gooch Milling & Elevator Co.Supreme Court of the United States · 1944
- Green v. CommissionerUnited States Tax Court · 1946
- Hale v. CommissionerUnited States Tax Court · 1942
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