Paulson v. Commissioner

*735OPINION.

Lansdon :

The pleadings and proof advanced at the hearing establish all the facts pertinent to this controversy. The only question for us to determine is whether the amounts received by the assignees were income directly to them or whether it was in the first instance income to Paulson and by him given to his children after the receipt thereof. Did the “Assignments of Royalty ” divest Paulson of all ownership in the conveyed property and the right to receive income therefrom or were they merely agreements providing for the passing on of certain parts of the assignor’s income to the…