Simpson v. Commissioner
United States Board of Tax Appeals
REVOCABLE TRUSTS - INCOME TAXABLE TO GRANTOR. - By an indenture dated in 1923, petitioner created three trust estates, naming his sisters as the beneficiaries thereof. Petitioner reserved the right to terminate the trusts on the 31st day of December of any year subsequent to the year 1923 by giving 60 days' previous notice in writing to the trustee.
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REVOCABLE TRUSTS - INCOME TAXABLE TO GRANTOR. - By an indenture dated in 1923, petitioner created three trust estates, naming his sisters as the beneficiaries thereof. Petitioner reserved the right to terminate the trusts on the 31st day of December of any year subsequent to the year 1923 by giving 60 days' previous notice in writing to the trustee. Held, the income received by the trustee for the trust estate for the taxable calendar years 1927 and 1928 is taxable to petitioner, the grantor, under sections 219(g) and 166 of the Revenue Acts of 1926 and 1928, respectively. Clapp v. Heiner, 51…
1Opinion of the Court
JAMES SIMPSON, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Simpson v. Commissioner
Docket No. 61434.
United States Board of Tax Appeals
30 B.T.A. 999; 1934 BTA LEXIS 1239;
June 21, 1934, Promulgated
REVOCABLE TRUSTS - INCOME TAXABLE TO GRANTOR. - By an indenture dated in 1923, petitioner created three trust estates, naming his sisters as the beneficiaries thereof. Petitioner reserved the right to terminate the trusts on the 31st day of December of any year subsequent to the year 1923 by giving 60 days' previous notice in writing to the trustee. Held, the income received by the…
2Cases cited4 opinions
- Corliss v. BowersSupreme Court of the United States · 1930
- Reinecke v. SmithSupreme Court of the United States · 1933
- Ashforth v. CommissionerUnited States Board of Tax Appeals · 1932
- Simpson v. CommissionerUnited States Board of Tax Appeals · 1934