Stix v. Commissioner
United States Tax Court
Income of property transferred by petitioners' mother to two trusts, of one of which each of petitioners was designated as "primary beneficiary" and of which the two petitioners were trustees with broad discretionary powers, including authority to distribute income to their children and to invade corpus for their benefit or that of their children, held, taxable to petitioners under section 22(a), notwithstanding that the income was actually paid to the children in the tax…
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Income of property transferred by petitioners' mother to two trusts, of one of which each of petitioners was designated as "primary beneficiary" and of which the two petitioners were trustees with broad discretionary powers, including authority to distribute income to their children and to invade corpus for their benefit or that of their children, held, taxable to petitioners under section 22(a), notwithstanding that the income was actually paid to the children in the tax years. Edward J. Mallinckrodt, Jr., 2 T. C. 1128; affd. (C. C. A., 8th Cir.), 146 Fed. (2d) 1, followed.
1Opinion of the Court
Edgar R. Stix, Petitioner, v. Commissioner of Internal Revenue, Respondent. Lawrence C. Stix, Petitioner, v. Commissioner of Internal Revenue, Respondent
Stix v. Commissioner
Docket Nos. 603, 609, 604
United States Tax Court
4 T.C. 1140; 1945 U.S. Tax Ct. LEXIS 186;
April 17, 1945, Promulgated
Decisions will be entered for the respondent.
Income of property transferred by petitioners' mother to two trusts, of one of which each of petitioners was designated as "primary beneficiary" and of which the two petitioners were trustees with broad discretionary powers, including authority to distribute income…
Also in this document: Dissent.
2Cases cited8 opinions
- Helvering v. CliffordSupreme Court of the United States · 1940
- Corliss v. BowersSupreme Court of the United States · 1930
- Harrison v. SchaffnerSupreme Court of the United States · 1941
- Greene v. . GreeneNew York Court of Appeals · 1891
- Mallinckrodt v. CommissionerUnited States Tax Court · 1943
3 more not listed; retrieve them via the Exa API.