Commissioner v. Willson

ALLEN, Circuit Judge.

This petition to review an order of the United States Board of Tax Appeals involves a ruling of the Commissioner determining deficiencies in income taxes against the respondent in the amount of $5,561.54 for the year 1936 and $4,292.84 for the year 1937. The Commissioner added the income of the Frances S. Willson Trust to the net income reported by respondent for each of the taxable years, holding that the income was taxable to the respondent under Section 167, Revenue Act of 1936, 26 U.S.C.A. Int.Rev.Acts, page 895, and Article 167-1, Regulations 94.

The case arises out…