Lynch v. Commissioner
United States Board of Tax Appeals
The petitioner in 1924 created an irrevocable trust fund for the support and maintenance of his wife and their two children, in contemplation of a divorce, which was obtained later in that year. The petitioner retained no interest in the trust fund or the income therefrom except a reversionary interest of remote possibility. Held, that the income from the fund in 1927 is not taxable to the petitioner.
1Opinion of the Court
*437OPINION.
Smith :
The petitioner contends that the disputed item of $21,000, representing the interest upon the securities held by the Atlanta Trust Company, is not taxable to him, but represents income to the trust, which he contends was created by the agreement of June 5, 1924, and that the amount is taxable under the provisions of section 219 of the Revenue Act of 1926. The respondent contends, first, that no trust was created as alleged, and, second, that, if a valid trust did exist during the taxable year, the petitioner himself was the beneficiary in respect of the income in question and…
2Cases cited1 opinion
- Gould v. GouldSupreme Court of the United States · 1917
3Cited by8 opinions
- Brooks v. CommissionerUnited States Board of Tax Appeals · 1934
- Hyde v. CommissionerUnited States Board of Tax Appeals · 1934
- Longyear v. CommissionerUnited States Board of Tax Appeals · 1933
- Longyear v. CommissionerUnited States Board of Tax Appeals · 1933
- Handly v. CommissionerUnited States Board of Tax Appeals · 1934
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