Wenger v. Commissioner of Internal Revenue

This case came on to be heard upon the records and briefs and oral argument of counsel.

And it appearing that the petitioner created a trust under which she and her children were beneficiaries, the income of which, together with the corpus, might be distributed in amounts within the discretion of the trustee, when requested in writing by petitioner or any of her children, in case “any accident, sickness, calamity, misfortune, adversity, bereavement or loss, financially or otherwise,” should befall them;

And it appearing that the trustee, who is petitioner’s nephew and has been her trusted…