Hoover v. Commissioner
United States Board of Tax Appeals
Income of a trust created by petitioner for the benefit of his wife and children held taxable to petitioner by reason of his retention of direct and indirect benefits approximating ownership. Helvering v. Clifford,309 U.S. 331.
1Opinion of the Court
*790OPINION.
Opper:
The correctness of respondent’s inclusion in. petitioner’s income for the years 1935 and 1936 of the income of a trust created by him is the first contested issue. Originally respondent’s action was predicated only upon sections 166 and 167, Bevenue Act of 1934. The additional question of the applicability of section 22, as adjudicated in Helvering v. Clifford, 309 U. S. 331, has, however, been properly put in issue as the result of subsequent proceedings and is also open for consideration. Herbert W. Hoover, 42 B. T. A. 289.
For convenience, the taxability to petitioner of the…
2Cases cited2 opinions
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Helvering v. CliffordSupreme Court of the United States · 1940
3Cited by4 opinions
- Cullen v. CommissionerUnited States Tax Court · 1944
- Hoover v. CommissionerUnited States Board of Tax Appeals · 1940
- Laganas v. CommissionerUnited States Tax Court · 1959
- Wolcott v. CommissionerUnited States Board of Tax Appeals · 1940