Byerly v. Commissioner

Again we are called upon to review a decision of the Tax Court upholding the assessment of income tax deficiencies against the settlor in a family trust indenture. We have heretofore written numerous opinions relating to family trusts since the promulgation of the opinion of the Supreme Court in Helvering v. Clifford, 309 U.S. 331, 60 S.Ct. 554, 84 L.Ed. 788. The first of our series’ was Altmaier v. Commissioner, 6 Cir., 116 F.2d 162, in which certiorari was denied, 312 U.S. 706, 61 S.Ct. 827, 85 L.Ed. 1138. Our opinions in this field of tax litigation were collated, to the date of its…