Reid Trust v. Commissioner
United States Tax Court
1. Held, on the facts involved, that the Court's conclusion is not governed by that of a common pleas court in Ohio. 2. A trust instrument provided benefits for three children. Held, on the facts presented, that one trust, and not three, was created.
1Opinion of the Court
OPINION.
Disney, Judge:
This case involves income tax liability for the years 1941 and 1942, as to which deficiencies were determined by the Commissioner in the amounts of $3,536.33 and $2,119.32, respectively. The single question presented is whether or not a certain instrument provided for only one trust for three children, or three trusts, one for each child. The petitioner contends first that in fact the instrument provided for three trusts and, further, that this Court is bound by a judgment of the Court of Common Pleas of Cuyahoga County, Ohio, in which the trust instrument here involved…
2Cases cited2 opinions
- Freuler v. HelveringSupreme Court of the United States · 1934
- US Trust Co. v. Commissioner of Internal RevenueSupreme Court of the United States · 1936
3Cited by16 opinions
- Estate of Sweet v. CommissionerUnited States Tax Court · 1955
- Lincoln Electric Co. Employees' Profit-Sharing Trust v. CommissionerUnited States Tax Court · 1950
- Kelly's Trust v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1948
- Second National Bank of New Haven v. United StatesDistrict Court, D. Connecticut · 1963
- Estate of Farish v. United StatesDistrict Court, S.D. Texas · 1964
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