Young v. Commissioner
United States Tax Court
1. Income -- Family Trusts. -- The income of trusts created by the petitioner for members of his family, held, taxable to him under section 22 (a), I. R. C. 2. Dividends -- Transfer of Assets for Less Than Fair Market Value. -- G Corporation transferred securities at less than fair market value to trusts created by the controlling stockholders of Y Corporation. Y Corporation owned all of the stock of G Corporation.
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1. Income -- Family Trusts. -- The income of trusts created by the petitioner for members of his family, held, taxable to him under section 22 (a), I. R. C. 2. Dividends -- Transfer of Assets for Less Than Fair Market Value. -- G Corporation transferred securities at less than fair market value to trusts created by the controlling stockholders of Y Corporation. Y Corporation owned all of the stock of G Corporation. Held, that the transfers represented distributions of taxable dividends to Y Corporation to the extent of the available earnings of G Corporation and also represented the…
1Opinion of the Court
OPINION.
MuRdock, Judge:
The Commissioner has held that the income of the four trusts created by Young is all taxable to him. He aj-gues that this determination was proper under section 22 (a) of the Revenue Act of 1936, as interpreted by the courts, particularly by the Supreme Court in Helvering v. Clifford, 309 U. S. 331. The petitioner gave himself broad administrative powers over the trusts, including the investment of the trust funds and the distribution of the trust income and principal. The beneficiaries were members of his immediate family. He exercised the powers which he gave himself.…
2Cases cited7 opinions
- Helvering v. CliffordSupreme Court of the United States · 1940
- Lucas v. EarlSupreme Court of the United States · 1930
- Helvering v. HorstSupreme Court of the United States · 1940
- General Utilities & Operating Co. v. HelveringSupreme Court of the United States · 1935
- Palmer v. CommissionerSupreme Court of the United States · 1937
2 more not listed; retrieve them via the Exa API.
3Cited by28 opinions
- Riss v. CommissionerUnited States Tax Court · 1971
- Epstein v. CommissionerUnited States Tax Court · 1969
- Dellinger v. CommissionerUnited States Tax Court · 1959
- Dean v. CommissionerUnited States Tax Court · 1947
- Hearst Corp. v. CommissionerUnited States Tax Court · 1950
23 more not listed; retrieve them via the Exa API.