Cowles v. Commissioner
United States Tax Court
Petitioner is a life beneficiary and a cotrustee of a trust created by his father. He also has a power of appointment over the remainder. Under article I, section 1 of the trust indenture the trustees are required to pay the entire net income of the trust to petitioner "if he demands it."
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Petitioner is a life beneficiary and a cotrustee of a trust created by his father. He also has a power of appointment over the remainder. Under article I, section 1 of the trust indenture the trustees are required to pay the entire net income of the trust to petitioner "if he demands it." Under article II, section 4, the trustees may in their discretion take out policies of life insurance on petitioner's life and charge the premiums thereof "to the income of the Trust Estate." In the taxable year the trustees exercised their discretion and took out a policy on petitioner's life and charged…
1Opinion of the Court
OPINION.
Black, Judge:
The sole issue in this proceeding is whether petitioner is taxable on that portion, $3,229.20, of the income of the Alfred Cowles III trust, of which petitioner was the life beneficiary, that was used by the trustees to pay the first premium on a life insurance policy taken out by the trustees on petitioner’s life. During the taxable year 1941 the trust had a net income, before applying section 162 (b) of the Internal Revenue Code, of $30,939.21. The trustees used $3,229.20 of this income to pay the above mentioned premium and distributed the balance of $27,710.01 to…
2Cases cited2 opinions
- Stix v. CommissionerUnited States Tax Court · 1945
- Bishop v. CommissionerUnited States Tax Court · 1945
3Cited by7 opinions
- Funk v. CommissionerUnited States Tax Court · 1946
- Grant v. CommissionerUnited States Tax Court · 1948
- Cowles v. CommissionerUnited States Tax Court · 1946
- Funk v. CommissionerUnited States Tax Court · 1946
- Funk v. CommissionerUnited States Tax Court · 1946
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