Small v. Commissioner

David Small, Petitioner, v. Commissioner of Internal Revenue, Respondent

Small v. Commissioner

Docket No. 175

United States Tax Court

3 T.C. 1142; 1944 U.S. Tax Ct. LEXIS 82;

July 21, 1944, Promulgated

Decision will be entered under Rule 50.

Income from a long term irrevocable trust of which petitioner was grantor and trustee, and over which the trustee had broad powers of management, held, not taxable to petitioner. Sec. 134, Revenue Act of 1943.

Thomas N. Tarleau, Esq., for the petitioner.

Walt Mandry, Esq., for the respondent.

Opper, Judge. Disney, J., concurring. Leech and Hill, JJ., agree with the…