Helvering v. Richter

Because the decision below, 114 F. 2d 452, was in conflict with that of the Circuit Court of Appeals for the Eighth Circuit in Helvering v. Hormel, 111 F. 2d 1, affirmed, ante, p. 552, we granted certiorari “limited to the first question presented by the petition for the writ.” 311 U. S. 641. The petition stated that question as follows:

“The taxpayer transferred securities to a third party in trust to pay the income to his wife. At the end of five years, or earlier if the beneficiary consented, the securities were to be transferred back to the taxpayer. The Board of Tax Appeals held that the…