MacManus v. Commissioner of Internal Revenue

SIMONS, Circuit Judge.

The single question presented for decision is whether for tax purposes the petitioner was a trustee in four separate and independent trusts originally set up by his father, Theodore F. MacManus, or whether, by the several mutations subsequent to the original creation of the trusts, they had become merged into a single trust with multiple beneficiaries. The question is important because if there is but a single trust, as the Commissioner of Internal; Revenue ruled, and the Board of Tax Appeals found, a substantial additional tax is payable. If there are four trusts as…