Ellinger v. Tax Commission

The record discloses that the income upon which the additional assessments involved herein are based was received in 1930 and 1931 by the appellant, Flora H. Ellinger, in the form of dividends from a common-law trust known as Michigan Avenue Syndicate, in which the appellant was the owner of 58.334 per cent of the outstanding certificates of interest. The trust was created by an agreement executed in 1914 to hold and rent certain real property located in Illinois, where all parties thereto resided and its business was transacted. The trust income, out of which the dividends were paid to the…