Morton v. Commissioner
United States Board of Tax Appeals
1. Petitioner created three trusts in each of which the trustee had the right to terminate the trust and revest the corpus in the grantor.
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1. Petitioner created three trusts in each of which the trustee had the right to terminate the trust and revest the corpus in the grantor. Held, the trusts are revocable and income thereof is taxable to petitioner, since trustee is not a person having a substantial adverse interest. 2. To one of these trusts created by him, petitioner assigned all of his interest under a certain trust created by his father, Joy Morton, one-third of the income of which was payable to petitioner. The income of this trust created by petitioner was to be accumulated. Under the terms of the Joy Morton trust,…
1Opinion of the Court
STERLING MORTON, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Morton v. Commissioner
Docket No. 91705.
United States Board of Tax Appeals
38 B.T.A. 1283; 1938 BTA LEXIS 756;
December 6, 1938, Promulgated
1. Petitioner created three trusts in each of which the trustee had the right to terminate the trust and revest the corpus in the grantor. Held, the trusts are revocable and income thereof is taxable to petitioner, since trustee is not a person having a substantial adverse interest.
2. To one of these trusts created by him, petitioner assigned all of his interest under a certain…
2Cases cited1 opinion
- Morton v. CommissionerUnited States Board of Tax Appeals · 1938