BLANEY v. COMMISSIONER
United States Board of Tax Appeals
The petitioner, under a trust established by the will of her father, had an equitable life interest therein consisting of the right to receive one-sixth of the income of the trust. On February 21, 1921, petitioner, in consideration of love and affection, assigned to her husband and her children portions of her right to receive such income from the trust.
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The petitioner, under a trust established by the will of her father, had an equitable life interest therein consisting of the right to receive one-sixth of the income of the trust. On February 21, 1921, petitioner, in consideration of love and affection, assigned to her husband and her children portions of her right to receive such income from the trust. Payments, pursuant to the right assigned, were thereafter made by the trustees to the assignees, the first payment in 1921 of $2,250 being made from funds accumulated prior to the assignments. Held, that the amount of $2,250 is income to…
1Opinion of the Court
*1317OPINION.
Love :
The petitioner contends that her assignees under the assignments of February 21, 1921, became substituted beneficiaries of a portion of the trust income to the extent of the respective assignments, and that she, the assignor, ceased to be a beneficiary of the trust to the extent of the portion assigned.
In support of this position it is urged that the assignments irrevocably vested title in the respective assignees to the portions of the trust income assigned prior to the accrual or receipt thereof to or by the petitioner.
The Commissioner, on the other hand, contends that by the…
2Cases cited3 opinions
- Security Bank of New York v. CallahanMassachusetts Supreme Judicial Court · 1915
- Buzzell v. R. H. White Co.Massachusetts Supreme Judicial Court · 1915
- Boston Safe Deposit & Trust Co. v. LukeMassachusetts Supreme Judicial Court · 1915
3Cited by10 opinions
- McDonald v. CommissionerUnited States Board of Tax Appeals · 1933
- Dodge v. CommissionerUnited States Board of Tax Appeals · 1933
- BLANEY v. COMMISSIONERUnited States Board of Tax Appeals · 1928
- Browning v. CommissionerUnited States Board of Tax Appeals · 1929
- Chicago Title & Trust Co. v. CommissionerUnited States Board of Tax Appeals · 1935
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