Huntington Nat'l Bank v. Commissioner
United States Board of Tax Appeals
1. Trust indenture construed to create one trust with two beneficiaries of the corpus, and not two trusts, each with a single beneficiary. 2. On December 28, 1927, the petitioner placed an order with a broker to sell, and the broker sold, certain stock, crediting the petitioner's account with the selling price and delivering to the purchaser certificates other than those held by the petitioner.
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1. Trust indenture construed to create one trust with two beneficiaries of the corpus, and not two trusts, each with a single beneficiary. 2. On December 28, 1927, the petitioner placed an order with a broker to sell, and the broker sold, certain stock, crediting the petitioner's account with the selling price and delivering to the purchaser certificates other than those held by the petitioner. On December 29, 1927, the petitioner delivered its certificates to the broker, which certificates, at its request, were reissued in favor of and delivered to the broker on December 30, 1927. The broker…
1Opinion of the Court
THE HUNTINGTON NATIONAL BANK, TRUSTEE OF JANET AND JEAN RUNKLE, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Huntington Nat'l Bank v. Commissioner
Docket No. 53535.
United States Board of Tax Appeals
32 B.T.A. 342; 1935 BTA LEXIS 961;
April 5, 1935, Promulgated
1. Trust indenture construed to create one trust with two beneficiaries of the corpus, and not two trusts, each with a single beneficiary.
2. On December 28, 1927, the petitioner placed an order with a broker to sell, and the broker sold, certain stock, crediting the petitioner's account with the selling price and delivering…
2Cases cited1 opinion
- Huntington Nat'l Bank v. CommissionerUnited States Board of Tax Appeals · 1935