Legal Opinion

Bowers v. Commissioner

United States Board of Tax Appeals

Decided May 22, 1936No. Docket No. 79209Published

The settlor of a trust, until the time of his death, could change the beneficiaries or alter their proportionate interests in the trust by the exercise of a power therein reserved. Held, the principal of the trust is includable in his gross estate.

1Opinion of the Court

STEWART W. BOWERS, TRUSTEE, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Bowers v. Commissioner

Docket No. 79209.

United States Board of Tax Appeals

34 B.T.A. 597; 1936 BTA LEXIS 675;

May 22, 1936, Promulgated

The settlor of a trust, until the time of his death, could change the beneficiaries or alter their proportionate interests in the trust by the exercise of a power therein reserved. Held, the principal of the trust is includable in his gross estate.

Spotswood D. Bowers, Esq., for the petitioner.

L. S. Pendleton, Esq., for the respondent.

SEAWELL

The taxes in controversy in this…

2Cases cited21 opinions

  1. Knowlton v. MooreSupreme Court of the United States · 1900
  2. Reinecke v. Northern Trust Co.Supreme Court of the United States · 1929
  3. Chase National Bank v. United StatesSupreme Court of the United States · 1929
  4. Young Men's Christian Assn. of Columbus v. DavisSupreme Court of the United States · 1924
  5. Porter v. CommissionerSupreme Court of the United States · 1933

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