Commissioner of Internal Revenue v. Jonas

AUGUSTUS N. HAND, Circuit Judge.

The question raised by this appeal of the Commissioner of Internal Revenue from the United States Board of Tax Appeals is whether the income derived in the year 1935 from two trusts created by Louise B. Jonas for her two sons is taxable to her under Section 22 (a) of the Revenue Act of 1934, 26 U.S.C.A.Int.Rev.Acts, page 669. The trusts were each limited to a period of ten years, at the expiration of which, or upon the prior death of the beneficiary, the principal with any accumulated income was to revert to the settlor. Whether liability to pay income taxes…