Bach v. Rothensies

GOODRICH, Circuit Judge.

Anthony J. Drexel died on December 14, 1934. Mr. Drexel was, in his lifetime, the life beneficiary of a one-quarter interest in the income of a trust created under the will of his father many years before. The terms of the trust prohibited the payment of income to the beneficiaries prior to its collection and further prohibited the latter from anticipating or enjoying income prior to its receipt and distribution by the trustees. Both the decedent taxpayer and the trustees maintained books of account on a cash receipts and disbursements basis.

In making the deceased…