Preston's Estate v. Commissioner of Internal Revenue

The question here presented is whether the trust which we held valid in Preston v. Commissioner of Internal Revenue, 2 Cir., 132 F.2d 763 was revocable by the grantor. We then held that the grantor, Preston, could take deductions on his income tax return for the interest he paid' on his personal bond under seal which became the corpus of the trust. His obligation to pay such interest had been established by the decision of the state court, United States Trust Co., of New York v. Preston, 264 App.Div. 152, 34 N.Y.S.2d 646, and familiarity with the opinion in each of those easqs will be assumed.