Legal Opinion

Arthur H. Ingle v. Commissioner

United States Tax Court

Decided August 26, 1949No. Docket No. 17082UnpublishedCited by 1 opinion

Under a trust agreement executed in 1929, as amended, taxpayer reserved the right and power to change any beneficiary or beneficiaries or the proportionate interest of any beneficiary or beneficiaries, except to revest title to principal or income in himself. The net income was payable quarterly to taxpayer's two adult daughters.

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Under a trust agreement executed in 1929, as amended, taxpayer reserved the right and power to change any beneficiary or beneficiaries or the proportionate interest of any beneficiary or beneficiaries, except to revest title to principal or income in himself. The net income was payable quarterly to taxpayer's two adult daughters. Upon the death of a beneficiary, the principal of the fund set aside for her and any accrued income was payable to the taxpayer-grantor or his estate. The net income of the trust during 1944 was paid to the two daughters. The trust agreement contained a broad…

1Opinion of the Court

Arthur H. Ingle v. Commissioner.

Arthur H. Ingle v. Commissioner

Docket No. 17082.

United States Tax Court

1949 Tax Ct. Memo LEXIS 94; 8 T.C.M. (CCH) 776; T.C.M. (RIA) 49209;

August 26, 1949

Under a trust agreement executed in 1929, as amended, taxpayer reserved the right and power to change any beneficiary or beneficiaries or the proportionate interest of any beneficiary or beneficiaries, except to revest title to principal or income in himself. The net income was payable quarterly to taxpayer's two adult daughters. Upon the death of a beneficiary, the principal of the fund set aside for her and…

2Cases cited8 opinions

  1. Helvering v. CliffordSupreme Court of the United States · 1940
  2. Helvering v. HorstSupreme Court of the United States · 1940
  3. Corliss v. BowersSupreme Court of the United States · 1930
  4. Helvering v. StuartSupreme Court of the United States · 1942
  5. Harrison v. SchaffnerSupreme Court of the United States · 1941

3 more not listed; retrieve them via the Exa API.

3Cited by1 opinion

  1. Ingle v. McGowan Collector of Internal RevenueCourt of Appeals for the Second Circuit · 1951

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