Booth v. Commissioner
United States Tax Court
Income from trust created by petitioner for his wife and applied by her without his direction or control to payment of insurance premiums on his life, held, not taxable to him. Henry A. B. Dunning, 36 B. T. A. 1222, distinguished.
1Opinion of the Court
opinion-.
Oppee, Judge:
Respondent’s view of the facts as set forth in his brief “may be summarized as follows: Petitioner * * * did not propose to continue premium payments, but his wife, not wishing to lose the benefit of past premium benefits * * * proposed to pay the premiums with income from the securities set aside for her. That proposal had his approval.”
This statement of the operative facts seems to us on its face to distinguish the present proceeding from Henry A. B. Dunning, 36 B. T. A. 1222. The trust income in that case was held taxable to the husband grantor on evidence that he…
2Cases cited3 opinions
- Helvering v. StuartSupreme Court of the United States · 1942
- Cartinhour v. CommissionerUnited States Tax Court · 1944
- Stuart v. CommissionerUnited States Tax Court · 1943
3Cited by1 opinion
- Booth v. CommissionerUnited States Tax Court · 1944