Richards v. Commissioner of Internal Revenue

RIVES, Circuit Judge.

The single question presented for review is whether [under Section 22(a) of the Internal Revenue Code, 26 U.S.C.A., as interpreted in Helvering v. Clifford, 309 U.S. 331, 60 S.Ct. 554, 84 L.Ed. 788] the Tax Court correctly held that the taxpayers are accountable for the dividends on certain shares of stock to which they retained the legal title although an interest in the shares had been donated in trust for their children.

The facts were all stipulated, subject to the right of either party to introduce further evidence. One additional item offered by the petitioner was…