Price v. Commissioner of Internal Revenue

MARTIN, Circuit Judge.

On petitions of H. C. Price for review of decisions of the United States Board of Tax Appeals, we must determine whether the income from a trust created by him was properly held taxable to him for 1934, 1935 and 1936, under Section 22(a) of the respective Revenue Acts of 1934 and 1936, 26 U.S.C.A. Int.Rev.Acts, pages 669, 825.

From the findings of fact of the Board of Tax Appeals, it appears that on October 1, 1923, the petitioner transferred in trust 250 shares of common stock of the Hoover Company, in which he was actively interested, to a Canton, Ohio, bank as trustee…