Ives v. Commissioner
United States Board of Tax Appeals
1. Certain revocable trust instruments of the character shown in the findings of fact were executed by the petitioners, May 1, 1923, and remained revocable during that year. Held, the income arising from such trusts during that year is taxable to the petitioners. 2. In 1924 the aforesaid trusts were revoked and other trusts of similar character except irrevocable in nature were made by petitioners.
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1. Certain revocable trust instruments of the character shown in the findings of fact were executed by the petitioners, May 1, 1923, and remained revocable during that year. Held, the income arising from such trusts during that year is taxable to the petitioners. 2. In 1924 the aforesaid trusts were revoked and other trusts of similar character except irrevocable in nature were made by petitioners. Held, the latter trusts operated as absolute assignments or transfers of property and property rights and the income arising therefrom in 1928 and 1929, the years in issue, is not taxable to the…
1Opinion of the Court
*829OPINION.
Seawell:
The deficiencies in income taxes asserted by the respondent are for the years 1923, 1928, and 1929. The statutes involved, though not here quoted, are sections 212 (a), 213 (a), 218 (a), (b), (c), and 224 of the Revenue Act of 1921, and sections 21, 22 (a), 181,182 (a), 183,184, and 189 of the Revenue Act of 1928.
The record shows quite clearly that in executing the trust instruments bearing dates of May 1, 1923, and February 15, 1924, as set, forth in our findings of fact, it was the intent of petitioners to reduce their tax liability by transferring their interests in their…
2Cases cited11 opinions
- Lucas v. EarlSupreme Court of the United States · 1930
- Corliss v. BowersSupreme Court of the United States · 1930
- Burnet v. LeiningerSupreme Court of the United States · 1932
- Burnet v. GuggenheimSupreme Court of the United States · 1933
- Burnet v. WellsSupreme Court of the United States · 1933
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3Cited by4 opinions
- Hanson v. BirminghamDistrict Court, N.D. Iowa · 1950
- Frank Trust of 1927 v. CommissionerUnited States Board of Tax Appeals · 1941
- Ives v. CommissionerUnited States Board of Tax Appeals · 1934
- Nathan v. CommissionerUnited States Tax Court · 1943