Legal Opinion

Cowles v. Commissioner

United States Tax Court

Decided January 9, 1946No. Docket No. 6001Published

Petitioner is a life beneficiary and a cotrustee of a trust created by his father. He also has a power of appointment over the remainder. Under article I, section 1 of the trust indenture the trustees are required to pay the entire net income of the trust to petitioner "if he demands it."

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Petitioner is a life beneficiary and a cotrustee of a trust created by his father. He also has a power of appointment over the remainder. Under article I, section 1 of the trust indenture the trustees are required to pay the entire net income of the trust to petitioner "if he demands it." Under article II, section 4, the trustees may in their discretion take out policies of life insurance on petitioner's life and charge the premiums thereof "to the income of the Trust Estate." In the taxable year the trustees exercised their discretion and took out a policy on petitioner's life and charged…

1Opinion of the Court

Alfred Cowles, Petitioner, v. Commissioner of Internal Revenue, Respondent

Cowles v. Commissioner

Docket No. 6001

United States Tax Court

6 T.C. 14; 1946 U.S. Tax Ct. LEXIS 322;

January 9, 1946, Promulgated

Decision will be entered for the respondent.

Petitioner is a life beneficiary and a cotrustee of a trust created by his father. He also has a power of appointment over the remainder. Under article I, section 1 of the trust indenture the trustees are required to pay the entire net income of the trust to petitioner "if he demands it." Under article II, section 4, the trustees may in their…

2Cases cited3 opinions

  1. Stix v. CommissionerUnited States Tax Court · 1945
  2. Cowles v. CommissionerUnited States Tax Court · 1946
  3. Bishop v. CommissionerUnited States Tax Court · 1945

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