Commissioner v. Clark

SWAN, Circuit Judge.

The taxpayer is the life beneficiary of several trusts under the terms of which the trustees were required to accumulate the income during his minority, to pay him the accumulated income upon his becoming 21 years of age, and thereafter to pay him the income for life, with remainders over. The taxpayer reached majority on November 16, 1938 and received on that date the accumulated income. It included income totaling $63,127.12 which the trustees had collected during 1938 before November 16th. They reported such income as taxable to their respective trusts and paid the…