Legal Opinion

Reizenstein v. Commissioner

United States Tax Court

Decided June 30, 1954No. Docket No. 39806Published

Trust Income -- Taxable to Grantor -- Parol Trust -- Secs. 22 (a), 166, and 167, I. R. C. -- The record fails to establish that there were provisions of a parol trust for a minor son stated by the petitioner and understood by his wife as trustee which would relieve him of tax on the income of the trust.

1Opinion of the Court

Louis J. Reizenstein, Petitioner, v. Commissioner of Internal Revenue, Respondent

Reizenstein v. Commissioner

Docket No. 39806

United States Tax Court

22 T.C. 843; 1954 U.S. Tax Ct. LEXIS 161;

June 30, 1954, Filed. June 30, 1954, Filed

Decision will be entered for the respondent.

Trust Income -- Taxable to Grantor -- Parol Trust -- Secs. 22 (a), 166, and 167, I. R. C. -- The record fails to establish that there were provisions of a parol trust for a minor son stated by the petitioner and understood by his wife as trustee which would relieve him of tax on the income of the trust.

Louis Caplan, Esq.,…

2Cases cited6 opinions

  1. Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
  2. Helvering v. CliffordSupreme Court of the United States · 1940
  3. Commissioner of Internal Revenue v. BuckCourt of Appeals for the Second Circuit · 1941
  4. Brown v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1942
  5. Moskin v. JohnsonDistrict Court, S.D. New York · 1953

1 more not listed; retrieve them via the Exa API.

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API