Ewald v. Commissioner of Internal Revenue

HAMILTON, Circuit Judge.

Petitioner asks for a review of the decision of the Tax Court of the United States upholding the determination by the respondent of income tax deficiencies against the petitioner for the years 1936, 1937, 1939 and 1940.

Petitioner on June 27, 1929, created in writing an irrevocable trust in favor of herself and her children and their descendants. She named her husband, Henry T. Ewald, trustee and empowered him to distribute to petitioner during her lifetime such portions of the net income from the trust as he might deem proper and upon her death the trustee was likewise…