Cartinhour v. Commissioner
United States Tax Court
A husband and wife joined in the creation of a trust for the benefit of their children, the husband contributing non-income-producing insurance policies upon his life and the wife contributing income-producing properties. The income, though not specifically required by the terms of the trust to be so used, was applied to the payment of premiums upon the insurance policies.
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A husband and wife joined in the creation of a trust for the benefit of their children, the husband contributing non-income-producing insurance policies upon his life and the wife contributing income-producing properties. The income, though not specifically required by the terms of the trust to be so used, was applied to the payment of premiums upon the insurance policies. The Commissioner included the income of the trust in the gross income of each petitioner (husband and wife). Held: (1) The income is not taxable to the husband under section 22 (a), I. R. C., or under Helvering v. Clifford,…
1Opinion of the Court
W. C. Cartinhour, Petitioner, v. Commissioner of Internal Revenue, Respondent. Kathleen Gager Cartinhour, Petitioner, v. Commissioner of Internal Revenue, Respondent
Cartinhour v. Commissioner
Docket Nos. 417, 418, 112706, 112707
United States Tax Court
3 T.C. 482; 1944 U.S. Tax Ct. LEXIS 164;
March 20, 1944, Promulgated
Decision will be entered under Rule 50.
A husband and wife joined in the creation of a trust for the benefit of their children, the husband contributing non-income-producing insurance policies upon his life and the wife contributing income-producing properties. The income, though…
Also in this document: Dissent.
2Cases cited18 opinions
- Helvering v. CliffordSupreme Court of the United States · 1940
- Hormel v. HelveringSupreme Court of the United States · 1941
- Helvering v. StuartSupreme Court of the United States · 1942
- Freuler v. HelveringSupreme Court of the United States · 1934
- Burnet v. WellsSupreme Court of the United States · 1933
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