Whiteley v. Commissioner
United States Tax Court
Income from certain irrevocable trusts which petitioner created in 1931 for the benefit of his eight children, who were then minors, and in which he made himself trustee with broad powers of administrative control, held not taxable to petitioner under section 22 (a) and the Supreme Court's decision in Helvering v. Clifford, 309 U.S. 331. Held, further, that, assuming that certain provisions of the trusts conferring upon petitioner's wife the power to use so much of the…
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Income from certain irrevocable trusts which petitioner created in 1931 for the benefit of his eight children, who were then minors, and in which he made himself trustee with broad powers of administrative control, held not taxable to petitioner under section 22 (a) and the Supreme Court's decision in Helvering v. Clifford, 309 U.S. 331. Held, further, that, assuming that certain provisions of the trusts conferring upon petitioner's wife the power to use so much of the income of the trusts for the support, education, and maintenance of the minor children as she saw proper would cause the net…
1Opinion of the Court
J. O. Whiteley, Petitioner, v. Commissioner of Internal Revenue, Respondent
Whiteley v. Commissioner
Docket No. 1575
United States Tax Court
3 T.C. 1265; 1944 U.S. Tax Ct. LEXIS 65;
August 23, 1944, Promulgated
Decision will be entered under Rule 50.
Income from certain irrevocable trusts which petitioner created in 1931 for the benefit of his eight children, who were then minors, and in which he made himself trustee with broad powers of administrative control, held not taxable to petitioner under section 22 (a) and the Supreme Court's decision in Helvering v. Clifford, 309 U.S. 331. Held, further,…
2Cases cited3 opinions
- Helvering v. CliffordSupreme Court of the United States · 1940
- Helvering v. StuartSupreme Court of the United States · 1942
- Whiteley v. CommissionerUnited States Tax Court · 1944