Letts v. Commissioner
United States Board of Tax Appeals
The settlor of a trust, established pursuant to an agreement made with his wife in contemplation of divorce, held, not taxable on the trust income distributed to his divorced wife for her maintenance and support where the divorce decree releasing him from all obligation to support was not subject to later modification and the settlor made no guarantees of income or principal in the trust instrument.
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The settlor of a trust, established pursuant to an agreement made with his wife in contemplation of divorce, held, not taxable on the trust income distributed to his divorced wife for her maintenance and support where the divorce decree releasing him from all obligation to support was not subject to later modification and the settlor made no guarantees of income or principal in the trust instrument. Helvering v. Fuller,310 U.S. 69; held, further, the settlor is taxable on the amounts of trust income distributed to his divorced wife and used by her for the support of his minor children.
1Opinion of the Court
ARTHUR LETTS, JR., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Letts v. Commissioner
Docket No. 92857.
United States Board of Tax Appeals
41 B.T.A. 1172; 1940 BTA LEXIS 1093;
May 16, 1940, Promulgated
The settlor of a trust, established pursuant to an agreement made with his wife in contemplation of divorce, held, not taxable on the trust income distributed to his divorced wife for her maintenance and support where the divorce decree releasing him from all obligation to support was not subject to later modification and the settlor made no guarantees of income or principal in the…
2Cases cited12 opinions
- Anderson v. WilsonSupreme Court of the United States · 1933
- Helvering v. FitchSupreme Court of the United States · 1940
- Helvering v. LeonardSupreme Court of the United States · 1940
- Helvering v. FullerSupreme Court of the United States · 1940
- Sweeney v. SweeneyNevada Supreme Court · 1919
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