Estate of Rosset v. Commissioner

1. Decedent, Barnet L. Rosset, was the major stockholder and president of a trust company. He acted as trust manager, corporation officer or director in various corporate reorganizations which the trust company handled. He also appraised property and operated the Office of Public Administrator of Cook County, Illinois, for the trust company. He paid over to the trust company most of the fees received from such activities. Held, the amounts received by decedent and paid over to the trust company were received in his capacity as its employee or agent and were not includible in his gross income.…