McCutchin v. Commissioner

McCORD, Circuit Judge.

The Commissioner determined income tax deficiencies for 1940 against Alex McCutchin and Alma McCutchin, husband and wife, by including ill their community gross income the income from four trusts jointly established by taxpayers with community property in 1939. The Tax Court redetermined fine deficiencies, holding that taxpayers were not taxable oti income from two of the trusts in favor of their minor children, but that under Section 22(a) of the Internal Revenue Code, 26 U.S.C.A. Int.Rev.Ccde, § 22(a), and the Clifford Doctrine1 they were taxable on the income oí two…