Stockstrom v. Commissioner of Internal Revenue

THOMAS, Circuit Judge.

This is a petition to review a decision of the Tax Court of the United States (4 T.C 5) redetermining income tax deficiencies for the calendar years 1939, 1940, and 1941 due from Bertha Stockstrom, who died December 9, 1941. The controversy involves the income for the taxable years from three trusts funds created by the decedent on March 31, 1939, when she was 74 years of age, for the benefit of her three adult children and seven grandchildren.

The Tax Court held that the income from the three trusts was taxable to her and her estate under § 22(a) of the Internal Revenue…