Penn v. Commissioner

THOMAS, Circuit Judge.

This petition to review a decision of the United States Board of Tax Appeals involves the income taxes of petitioner for the years 1934 and 1935. The question presented is whether the petitioner is taxable for the income derived from securities constituting the corpus of two trusts of which he was grantor and trustee and his two minor daughters were the beneficiaries.

The taxpayer is a resident of Des Moines, Iowa. On June • 7, 1934, he executed two declarations of trust identical' in form except that in one his daughter Lois Mary, aged 16, was named beneficiary, and in…