Mallinckrodt v. Nunan

SANBORN, Circuit Judge.

The Tax Court of the United States determined deficiencies in the income taxes due from petitioner for the calendar years 1934 to 1937, inclusive. 2 T.C. 1128. The deficiencies resulted from including in the petitioner’s income for each of the years the undistributed income of an irrevocable trust created by his father in 1918. By the terms of the instrument creating the trust, this undistributed income was payable to petitioner annually upon his request, but, if not paid to him at his request, it was to be added to the corpus of the trust estate at the end of each year.