Garland v. Commissioner
United States Board of Tax Appeals
1. Where the settlor of a trust reserves the power to borrow from the trust corpus up to $100,000 on his unsecured notes and reserves further all rights of the insured under certain insurance policies transferred to the trust, held, the trust is revocable within the meaning of section 166 of the Revenue Act of 1934. 2. Interest from municipal bonds issued under the California Municipal Improvement District Act of April 20, 1915, held, exempt from Federal income tax.
1Opinion of the Court
WILLIAM J. GARLAND AND GRACE O. GARLAND, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Garland v. Commissioner
Docket Nos. 93589, 95547.
United States Board of Tax Appeals
42 B.T.A. 324; 1940 BTA LEXIS 1027;
June 28, 1940, Promulgated
1. Where the settlor of a trust reserves the power to borrow from the trust corpus up to $100,000 on his unsecured notes and reserves further all rights of the insured under certain insurance policies transferred to the trust, held, the trust is revocable within the meaning of section 166 of the Revenue Act of 1934.
2. Interest from municipal bonds…
2Cases cited1 opinion
- Garland v. CommissionerUnited States Board of Tax Appeals · 1940