Sunderland v. Commissioner

McLAUGHLIN, Circuit Judge.

Petitioner, her husband and their two children are residents of New Jersey. In 1934 the husband created two identical trusts in favor of the children. Article 1, referring to income, says: “1. To collect and receive the rents, interest, income and dividends thereon, hereinafter referred to as income, and to pay or apply the net income therefrom, after deducting all proper charges and expenses to or for the use of Joan Sunderland during her natural life.” The principal of the funds *677is covered by Article 2 which provides that on the death of the particular child the…