Rovensky v. Commissioner
United States Board of Tax Appeals
A trust which provides that the income shall go to A until she reaches forty and the trust is then to terminate and the fund go to A, and if A dies before reaching forty, the grantor and another may terminate the trust and the fund is then to go either to the grantor or to one designated by the grantor and another, held not to vest in the grantor a power to revest the fund in himself within Revenue Act of 1934, section 166.
1Opinion of the Court
*703OPINION.
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For 1934 the Commissioner determined a deficiency of $3,783.14 in the petitioner’s individual income tax. The petitioner contests the holding that the income of a trust, $14,784, is taxable to him because, in the words of the deficiency notice:
* * * According to the terms of the trust instrument it is evident that you had retained a certain interest in the corpus of the trust and, therefore, same is held in. article 166, Regulations 86, to constitute a revocable trust, the income of which is taxable to you as grantor.
The facts are all stipulated and for the purpose of this…
2Cited by14 opinions
- Canfield v. CommissionerUnited States Tax Court · 1960
- Corning v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1939
- Helvering v. DunningCourt of Appeals for the Fourth Circuit · 1941
- Branch v. CommissionerUnited States Board of Tax Appeals · 1939
- Canfield v. CommissionerUnited States Tax Court · 1960
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