Buck v. Commissioner
United States Board of Tax Appeals
1. TRUST INCOME - TAXABILITY OF GRANTOR. - Income of a trust not taxable to the grantor under sections 22(a), 166, or 167 where he was not to receive the income, could not revoke the trust, and could not amend so as to receive income or principal but could amend to change beneficiaries and beneficiaries could revoke trust. 2. INCOME - INSURANCE INSTALLMENT. - Annual installment on a life insurance contract held exempt from tax under section 22(b)(1), Revenue Act of 1934.
1Opinion of the Court
*102OPINION.
Murdock:
Although the Commissioner in his notice of deficiency referred to both section 166 and section 167 to justify his inclusion of the trust income in the income of the petitioner, he now, apparently, seeks no support for his action in section 167, except as to a small amount mentioned in his alternative contention. Section 167 provides that where any part of the income of a trust is, or in the discretion of described persons may be, distributed or held for future distribution to the grantor or applied to the payment of premiums upon policies of insurance on the life of the…
2Cases cited1 opinion
- Poe v. SeabornSupreme Court of the United States · 1930
3Cited by7 opinions
- Commissioner of Internal Revenue v. BuckCourt of Appeals for the Second Circuit · 1941
- Carson v. CommissionerUnited States Tax Court · 1989
- Bissinger v. CommissionerUnited States Tax Court · 1943
- Buck v. CommissionerUnited States Board of Tax Appeals · 1940
- Carson v. CommissionerUnited States Tax Court · 1989
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