Whiteley v. Commissioner
United States Board of Tax Appeals
Petitioner's brother transferred in trust for her benefit certain stock, part of which was owned by petitioner, insurance taken out on petitioner's life, and a note of petitioner. Two days later petitioner executed a reciprocal trust with shares of the same stock, part of which was owned by her brother, and a note of her brother.
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Petitioner's brother transferred in trust for her benefit certain stock, part of which was owned by petitioner, insurance taken out on petitioner's life, and a note of petitioner. Two days later petitioner executed a reciprocal trust with shares of the same stock, part of which was owned by her brother, and a note of her brother. Held, that the petitioner was the grantor of the trust executed by her brother and that the income of the trust, part of which was used by the trustee to pay premiums on the life insurance, is taxable to petitioner under the provisions of section 22(a), 166, and 167…
1Opinion of the Court
PURDON SMITH WHITELEY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Whiteley v. Commissioner
Docket Nos. 92901, 92902.
United States Board of Tax Appeals
42 B.T.A. 316; 1940 BTA LEXIS 1026;
June 28, 1940, Promulgated
Petitioner's brother transferred in trust for her benefit certain stock, part of which was owned by petitioner, insurance taken out on petitioner's life, and a note of petitioner. Two days later petitioner executed a reciprocal trust with shares of the same stock, part of which was owned by her brother, and a note of her brother. Held, that the petitioner was the…
2Cases cited1 opinion
- Whiteley v. CommissionerUnited States Board of Tax Appeals · 1940