Brainard v. Commissioner
United States Board of Tax Appeals
In December 1927 petitioner declared a parol trust in all profits which might thereafter be derived by him from trading in securities during the year 1928, to be held by him in trust for the members of his family. Held, the profits so derived by the petitioner during 1928 are taxable to him as part of his gross income for that year.
1Opinion of the Court
MILLAR BRAINARD, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Brainard v. Commissioner
Docket No. 56985.
United States Board of Tax Appeals
32 B.T.A. 1036; 1935 BTA LEXIS 856;
July 25, 1935, Promulgated
In December 1927 petitioner declared a parol trust in all profits which might thereafter be derived by him from trading in securities during the year 1928, to be held by him in trust for the members of his family. Held, the profits so derived by the petitioner during 1928 are taxable to him as part of his gross income for that year.
John E. Hughes, Esq., for the petitioner.
Hartford…
2Cases cited1 opinion
- Brainard v. CommissionerUnited States Board of Tax Appeals · 1935