Jacobs v. Commissioner

HOLMES, Circuit Judge.

This is a petition to review an order of the Board of Tax Appeals sustaining a determination of the Commissioner that petitioner, as settlor of the Jacobs Trust, was taxable upon the entire trust income for the years 1935, 1936, and 1937. The question is whether the record contains substantial evidence to support the Board’s finding that the settlor retained such dominion and control over the property transferred as would entitle the Commissioner to treat him as owner of the corpus for income-tax purposes.

The property from which the income in question was derived was…