Angus J. Depinto and Margaret F. Depinto v. United States

SNEED, Circuit Judge:

Taxpayers Angus and Margaret DePinto appeal from the denial of their claims for refund of certain federal income taxes, interest, and penalty paid for the years 1964, 1965, and 1967. Two issues are presented on appeal: First, whether the Grantor Trust provisions of the Internal Revenue Code, 26 U.S.C. §§ 671 to 678, entitle appellants to include on their personal tax return the income and deductions reported during their bankruptcy by the bankruptcy trustee. Second, whether attorneys’ fees incurred in defense of a suit arising out of Angus De-Pinto’s service as a…