Reuter v. Commissioner

HOLMES, Circuit Judge.

This petition to review requires us to determine whether a conveyance in trust of the income from certain securities, made by the taxpayer to himself as trustee for the use and benefit of his wife, his father, and his mother, sufficiently alienated the title, possession, and control of the property from the grantor so as to relieve him from taxation upon the income thereof. To decide the question, we must analyze the terms and conditions of the trust to ascertain whether the conveyance is embraced within the purview of either Section 22(a) or 166 of the Internal Revenue…