Rosenblatt v. Commissioner
United States Tax Court
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
- Heller Trust v. CommissionerUnited States Tax Court · 1946
3Cited by6 opinions
- Trustee Corp. v. CommissionerUnited States Tax Court · 1964
- Peerless Weighing & Vending Machine Corp. v. CommissionerUnited States Tax Court · 1969
- Boucher v. CommissionerUnited States Tax Court · 1981
- Peerless Weighing & Vending Machine Corp. v. CommissionerUnited States Tax Court · 1969
- Rosenblatt v. CommissionerUnited States Tax Court · 1947
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