Helvering v. Fuller

This case raises the question of the circumstances under which income paid to the taxpayer’s divorced wife under a trust, the provisions of which have been approved in the divorce decree, is taxable to him. We granted certi-orari because of the asserted misapplication by the Circuit Court of Appeals of the rule of Douglas v. Willcuts, 296 U. S. 1, to these facts:

On July 25, 1930, respondent and his wife, residing in Connecticut, entered into an agreement in contemplation of divorce which provided, inter alia, for the creation by him of a trust of 60,380 shares of Class A common stock of the…