Commissioner of Internal Revenue v. Grosvenor

SWAN, Circuit Judge.

The question presented by this litigation is whether the 1929 income of two trusts created by the taxpayer for the support of his two minor daughters constitutes taxable income to him.

In 1927 Theodore P. Grosvenor established two trusts, one for each of his two infant daughters. By the terms of each trust, the trustee was to pay the net income to the settlor’s wife “to be expended by her for the support, maintenance and education” of the daughter named therein during her minority, “without any liability upon” Mrs. Grosvenor “to account for the expenditure of said income to…