Legal Opinion

Rosenblatt v. Commissioner

United States Tax Court

Decided June 25, 1947No. Docket Nos. 10104, 10105PublishedCited by 6 opinions

Income -- Revocable Trust -- Section 166 (1). -- Section 166(1) applies where four of six grantors retain power to revoke trust and revest in themselves title to a part of the trust corpus.

1Opinion of the Court

OPINION.

Murdock, Judge:

The Commissioner determined deficiencies in income tax as follows:

Doeket.No. Year Amount 10104 10105 1939 (1940 \I941 $180.30 307.72 377.64 Bernard A. and Gertrude Rosenblatt-Gertrude Rosenblatt...—

The parties have settled several issues and the two left for decision are: (1) Whether one-fourth of the income of a trust for each year is taxable to Gertrude Rosenblatt under section 166 of the Internal Revenue Code because the trust was revocable; (2) whether the Commissioner erred in allowing as a deduction for 1940 only two-fifths of an amount paid by the trust to cancel…

2Cases cited1 opinion

  1. Heller Trust v. CommissionerUnited States Tax Court · 1946

3Cited by6 opinions

  1. Trustee Corp. v. CommissionerUnited States Tax Court · 1964
  2. Peerless Weighing & Vending Machine Corp. v. CommissionerUnited States Tax Court · 1969
  3. Boucher v. CommissionerUnited States Tax Court · 1981
  4. Peerless Weighing & Vending Machine Corp. v. CommissionerUnited States Tax Court · 1969
  5. Rosenblatt v. CommissionerUnited States Tax Court · 1947

1 more not listed; retrieve them via the Exa API.

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API