Ayer v. Commissioner
United States Board of Tax Appeals
1. Petitioner, prior to the taxable year, created separate trusts for each of his five minor children. He named himself and his wife as trustees. The trusts were to last for the life of the respective beneficiaries. No power to revoke the trusts was reserved by the grantor or vested in anyone else.
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1. Petitioner, prior to the taxable year, created separate trusts for each of his five minor children. He named himself and his wife as trustees. The trusts were to last for the life of the respective beneficiaries. No power to revoke the trusts was reserved by the grantor or vested in anyone else. Held, the trusts were irrevocable and the income of the trusts is not taxable to petitioner under section 166, Revenue Act of 1934. 2. Each of the trust indentures provided that the trustees "may pay to the beneficiary of the trust so much of the net income as they may deem necessary for his…
1Opinion of the Court
FREDERICK AYER, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Ayer v. Commissioner
Docket No. 93019.
United States Board of Tax Appeals
45 B.T.A. 146; 1941 BTA LEXIS 1168;
September 18, 1941, Promulgated
1. Petitioner, prior to the taxable year, created separate trusts for each of his five minor children. He named himself and his wife as trustees. The trusts were to last for the life of the respective beneficiaries. No power to revoke the trusts was reserved by the grantor or vested in anyone else. Held, the trusts were irrevocable and the income of the trusts is not taxable to…
2Cases cited10 opinions
- Douglas v. WillcutsSupreme Court of the United States · 1935
- Reinecke v. SmithSupreme Court of the United States · 1933
- Freeman v. . CoitNew York Court of Appeals · 1884
- Creeley v. CreeleyMassachusetts Supreme Judicial Court · 1927
- Boeing v. CommissionUnited States Board of Tax Appeals · 1938
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