Wadewitz v. Commissioner
United States Tax Court
1. Petitioner Nettie Wadewitz and her husband Edward H. Wadewitz, as grantors, created a trust known as Trust # 1. Edward assigned to the trustees certain policies of insurance on his life; and Nettie at the same time assigned to the trustees certain shares of corporate stock.
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1. Petitioner Nettie Wadewitz and her husband Edward H. Wadewitz, as grantors, created a trust known as Trust # 1. Edward assigned to the trustees certain policies of insurance on his life; and Nettie at the same time assigned to the trustees certain shares of corporate stock. The trustees were to use the trust income, which during the taxable years consisted entirely of dividends from the stock contributed by Nettie, to pay premiums on the aforesaid policies, and to add any remaining income to corpus. The trust indenture provided that, after the death of Edward, the trustees were to collect…
1Opinion of the Court
OPINION.
Pierce, Judge:
The respondent determined deficiencies in the income taxes of Edward and Nettie Wadewitz for the years 1949,1950, and 1951, in the respective amounts of $8,861.80, $9,959.93, and $9,940.89.
The issues presented for decision are:(1) Whether the income of the E. H. Wadewitz Trust #1 for the calendar years 1949, 1950, and 1951 was held or accumulated for future distribution to petitioner Nettie Wadewitz (one of the grantors of said trust), so as to cause such trust income to be includible in her individual income, under the provisions of section 167(a) (1) of the Internal…
2Cases cited7 opinions
- Kent v. RothensiesCourt of Appeals for the Third Circuit · 1941
- Greenough v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1934
- Irish v. CommissionerUnited States Board of Tax Appeals · 1941
- Kent v. United StatesUnited States Court of Claims · 1945
- Phipps v. HelveringCourt of Appeals for the D.C. Circuit · 1941
2 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Wadewitz v. CommissionerUnited States Tax Court · 1959