Friedman v. Commissioner
United States Tax Court
Grantor of trusts of which the corpus was invested in stock of family corporations, of which children were beneficiaries, and of which he was trustee, with broad powers of management and with discretionary powers as to accumulation of income and invasion of corpus, held, taxable on income of the trusts under section 22 (a), I. R. C.
1Opinion of the Court
OPINION.
HakRON, Judge-.
The only question for decision is whether petitioner is taxable under section 22 (a) upon income of three trusts of which petitioner is trustee, as respondent has determined. Respondent relies upon the following in support of his determination: Helvering v. Clifford, 809 U. S. 331; Louis Stockstrom, 148 Fed. (2d) 491; Edison v. Commissioner, 148 Fed. (2d) 810; Funsten v. Commissioner, 148 Fed. (2d) 805; Williamson v. Commissioner, 132 Fed. (2d) 489.
During the existence of the trusts to date, no distributions of income have been made to the beneficiaries, and all of the…
2Cases cited5 opinions
- Helvering v. StuartSupreme Court of the United States · 1942
- Rentschler v. CommissionerUnited States Tax Court · 1943
- Stockstrom v. CommissionerUnited States Tax Court · 1944
- Morgan v. CommissionerUnited States Tax Court · 1945
- Chertoff v. CommissionerUnited States Tax Court · 1946
3Cited by1 opinion
- Friedman v. CommissionerUnited States Tax Court · 1946