Scott v. Commissioner of Internal Revenue

ALSCHULER, Circuit Judge.

Petitioner’s father, John E. Scott, owning a tenth interest in a large and lucrative business partnership, in 1911 made an agreement with his son Robert L. Scott whereby he conveyed this interest to Robert, who was to hold it in trust, to receive the net profits and earnings of the partnership distributed upon this share, and to pay them to the father during his life, and upon his death to divide the property, and all accumulations thereon, equally among the three sons (one of whom is petitioner), in which case the .sons were thereafter to pay to their mother, if…