Commissioner of Internal Revenue v. Taylor

CLARK, Circuit-Judge.

The respondent taxpayer seeks to avoid the impact of!k7vfery recent decision of the United Státfes Supreme Court.1 In 1934 he created'a tbust for the benefit of his four nephews and nieces.- By its terms it provides life- estates in' choses in action in the named children- with powers of appointment and remainders over. The provisions relevant to the principal case read:

“(a) Trustees shall divide the principal of this Trust iiito four equal shares, said shares being-represented respectively by the four children of Settlor’s brother, John M. Taylor, to wit: Priscilla…