Corning v. Commissioner

Petitioner created two trusts. In each, he reserved the right to remove and substitute himself or others as trustee, and the power to control the trustee as to investment of the corpus. Each trust agreement provided that the trustee might loan money to petitioner's estate without security or invest the corpus in any way without liability for loss if it had first secured his approval. Petitioner's father, who was a possible beneficiary in case petitioner died without direct descendants, was granted the right to amend the trust at any time and change its beneficial interests. The income of both…