Morton v. Commissioner
United States Board of Tax Appeals
Petitioner, a resident of Pennsylvania, declared a trust for the benefit of his mother, a resident of New Jersey. The trust was revocable by joint action of settlor and beneficiary. Held, that the income of the trust was not taxable to the petitioner either under section 166, Revenue Act of 1934, or, the petitioner having no duty of supporting his nonresident mother under the law of Pennsylvania, under section 167 or the principles of Douglas v. Willcuts,296 U.S. 1.
1Opinion of the Court
ARTHUR F. MORTON, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Morton v. Commissioner
Docket No. 91494.
United States Board of Tax Appeals
41 B.T.A. 742; 1940 BTA LEXIS 1150;
April 4, 1940, Promulgated
Petitioner, a resident of Pennsylvania, declared a trust for the benefit of his mother, a resident of New Jersey. The trust was revocable by joint action of settlor and beneficiary. Held, that the income of the trust was not taxable to the petitioner either under section 166, Revenue Act of 1934, or, the petitioner having no duty of supporting his nonresident mother under the law of…
2Cases cited2 opinions
- Douglas v. WillcutsSupreme Court of the United States · 1935
- Morton v. CommissionerUnited States Board of Tax Appeals · 1940