Bromley v. Commissioner
United States Board of Tax Appeals
Each of the petitioners created a trust in which his children were beneficiaries and in which the grantor and the other petitioners were trustees. Power was reserved to revest the corpus in the grantor upon the concurrence of all four trustees.
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Each of the petitioners created a trust in which his children were beneficiaries and in which the grantor and the other petitioners were trustees. Power was reserved to revest the corpus in the grantor upon the concurrence of all four trustees. Held that the income from the trusts was taxable to petitioners under section 219(g), Revenue Acts of 1924 and 1926, and section 166, Revenue Act of 1928, following Emma Louise Smith,23 B.T.A. 631 (reversed by Circuit Court on a ground which is not present in these proceedings).
1Opinion of the Court
OPINION.
Aeundell :
These proceedings, duly consolidated are brought for the redetermination of proposed deficiencies in income taxes as follows:
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In each proceeding a stipulation of facts was filed, which we incorporate herein by reference and adopt as our findings of fact.
The four petitioners are brothers. On December 19, 1921, each of the four petitioners executed a deed of trust, and in each trust *879the grantor and the three other petitioners were constituted trustees. Under the terms of each trust certain securities were transferred by the grantor to the trustees for the purpose…
2Cases cited1 opinion
- Reinecke v. Northern Trust Co.Supreme Court of the United States · 1929
3Cited by6 opinions
- Security First Nat'l Bank v. CommissionerUnited States Board of Tax Appeals · 1933
- Bowler v. CommissionerUnited States Board of Tax Appeals · 1934
- Bowler v. CommissionerUnited States Board of Tax Appeals · 1934
- Bromley v. CommissionerUnited States Board of Tax Appeals · 1932
- Grosvenor v. CommissionerUnited States Board of Tax Appeals · 1934
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