Legal Opinion

Knight v. Commissioner

United States Tax Court

Decided January 22, 1946No. Docket Nos. 5794, 5795, 5796, 5797PublishedCited by 1 opinion

Income -- Trusts. -- Petitioners, beneficiaries under trusts created by their father, are not taxable under section 22 (a) or section 162 on income of the trusts which they did not receive and which, under the terms of the trusts, they had no right to receive during the taxable years.

1Opinion of the Court

OPINION.

Mubdock, Judge:

The Commissioner determined deficiencies in income tax of the petitioners as follows:

[[Image here]]

The parties filed a stipulation of factSj stipulated certain other facts into the record, and introduced certain exhibits. All of the foregoing are adopted as the findings of fact. There is no dispute about any material fact.

The Commissioner has held in the case of each petitioner that all of the income of a trust created by W. W. Knight, the father of the petitioner, of which the petitioner was the principal beneficiary, must be included in the petitioner’s income “under…

2Cases cited2 opinions

  1. Walker, Trustee v. BrownOhio Court of Appeals · 1930
  2. Hopf v. United States Baking Co.Superior Court of Buffalo · 1892

3Cited by1 opinion

  1. Knight v. CommissionerUnited States Tax Court · 1946

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

Powered by the Exa API