Boynton v. Commissioner
United States Board of Tax Appeals
Agreement executed by petitioner and The Cleveland Trust Co.held not to constitute a trust within the meaning of section 219 of the Revenue Acts of 1918 and 1921.
1Opinion of the Court
*1361OPINION.
ARundbbb:
The question involved is the proper treatment to be accorded the income derived from property placed with the Cleveland Trust Co. under the terms of the instrument quoted in the findings of fact, and particularly whether the petitioner is entitled to deduct from his gross income claimed losses on the sale of securities which were held by the Cleveland Trust Co. under that agreement.
A consideration of the agreement discloses that all income was reserved exclusively to the-petitioner; he had not merely the power *1362to revoke but the power to modify the agreement; the duty of…
2Cited by4 opinions
- Ives v. CommissionerUnited States Board of Tax Appeals · 1934
- Boynton v. CommissionerUnited States Board of Tax Appeals · 1928
- Cleveland Trust Co. v. CommissionerUnited States Board of Tax Appeals · 1931
- McCrory v. CommissionerUnited States Board of Tax Appeals · 1932