Sun First National Bank of Orlando v. United States

I respectfully dissent because I cannot agree with the following express or implied findings and conclusions of the majority which, in my opinion, are unsupported by the facts or the law and are clearly erroneous:(1) That the settlor, Mrs. Jeanette Andersen, retained an interest in the corpus of the stock when she created the trust in 1941.(2) That Mrs. Andersen was the owner of, or had legal title to, the stock after the trust was created.(3) That Mrs. Andersen had control over the stock after she conveyed it to the trust in 1941.(4) That Mrs. Andersen, and not the trustees, sold the stock…