Morgan v. Commissioner
United States Tax Court
Grantors of trusts of which the corpus and accumulated income was invested in stock of wholly owned family corporations, of which their children and grandchildren were beneficiaries, and of which they were trustees with broad powers of management and with discretionary powers as to accumulation of income, held, taxable on income of trusts under section 22 (a) of the Internal Revenue Code.
1Opinion of the Court
OPINION.
Opper, Judge-.
These proceedings are brought for redetermination of deficiencies in income tax as follows:
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The proceedings challenge respondent’s inclusion under Internal Revenue Code, section 22 (a), in the respective petitioner’s taxable income of income from four trusts of which they were grantors. In making the determinations of deficiencies, respondent allocated the trust income to the petitioners upon the basis of the percentage of principal transferred by each petitioner to the respective trusts.
All of the facts are stipulated and are hereby found accordingly. They…
2Cases cited3 opinions
- Helvering v. CliffordSupreme Court of the United States · 1940
- Rentschler v. CommissionerUnited States Tax Court · 1943
- Stockstrom v. CommissionerUnited States Tax Court · 1944
3Cited by22 opinions
- Young v. CommissionerUnited States Tax Court · 1945
- Chertoff v. CommissionerUnited States Tax Court · 1946
- Jones v. CommissionerUnited States Tax Court · 1946
- Shapero v. CommissionerUnited States Tax Court · 1947
- Welch v. CommissionerUnited States Tax Court · 1947
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