Bagnall v. Commissioner

I dissent on two questions of law:(1) Under the controlling terms of the trust, its contribution to the taxpayer’s gross income is the net income of the trust estate. Each income is subject to a separate tax on a separate taxable entity, under different computations.' Failing to recognize this, the majority has erroneously held that, in computing the beneficiary’s tax, the gross income of the estate is to be considered as a part of the gross income of the beneficiary. In so doing it contravenes the Supreme Court decisions relied upon by the taxpayer and not mentioned in the majority opinion.…