Wynne v. Commissioner

WALKER, Circuit Judge.

The petitioners, trustees under an instrument which conveyed to them certain properties, in trust for the use and benefit of three named minors in portions oí a one-third interest to each beneficiary, complained of income tax deficiencies assessed against them for the years 1924, 1925, and 1926, for which years the petitioners made no returns of income of the trust estate. The petitioners contended that the trust instrument created three trusts, and that the income was properly returned in returns made by each of the beneficiaries for each of those years, each of which…