Heaslet v. Commissioner
United States Board of Tax Appeals
Prior to the taxable years petitioner established a trust for the benefit of his wife. The trust could be altered or amended by petitioner only with the consent of his wife. In 1937 petitioner and his wife entered into a separation agreement which provided for the payment of $100 per month and the continuation of payment of the trust income to the wife. This agreement was incorporated into a decree for alimony by the Ohio court.
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Prior to the taxable years petitioner established a trust for the benefit of his wife. The trust could be altered or amended by petitioner only with the consent of his wife. In 1937 petitioner and his wife entered into a separation agreement which provided for the payment of $100 per month and the continuation of payment of the trust income to the wife. This agreement was incorporated into a decree for alimony by the Ohio court. Held, petitioner is not taxable upon the trust income, (1) for the period prior to the separation agreement under section 167 of the Revenue Act of 1936, since…
1Opinion of the Court
JAMES G. HEASLET, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. *
Heaslet v. Commissioner
Docket No. 108421.
United States Board of Tax Appeals
47 B.T.A. 1006; 1942 BTA LEXIS 617;
November 10, 1942, Promulgated
Prior to the taxable years petitioner established a trust for the benefit of his wife. The trust could be altered or amended by petitioner only with the consent of his wife. In 1937 petitioner and his wife entered into a separation agreement which provided for the payment of $100 per month and the continuation of payment of the trust income to the wife. This agreement was…
2Cases cited2 opinions
- Helvering v. FullerSupreme Court of the United States · 1940
- Heaslet v. CommissionerUnited States Board of Tax Appeals · 1942