O'Laughlin v. Commissioner
United States Board of Tax Appeals
1. TRUST REVOCABLE AFTER TAXABLE YEAR. - Section 166 of the Revenue Act of 1934 applies where the grantor retained the right to revoke the trust after the close of the year 1934. 2. TRUST INCOME - TAXABLE TO GRANTOR. - Income of trusts taxable to grantor who had extensive control over and benefit from trusts, following Benjamin F. Wollman,31 B.T.A. 37, William C. Rands,34 B.T.A. 1107, and Warren H. Corning,36 B.T.A. 301. 3. DEDUCTION - LOSSES - SALES TO CLOSELY OWNED…
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1. TRUST REVOCABLE AFTER TAXABLE YEAR. - Section 166 of the Revenue Act of 1934 applies where the grantor retained the right to revoke the trust after the close of the year 1934. 2. TRUST INCOME - TAXABLE TO GRANTOR. - Income of trusts taxable to grantor who had extensive control over and benefit from trusts, following Benjamin F. Wollman,31 B.T.A. 37, William C. Rands,34 B.T.A. 1107, and Warren H. Corning,36 B.T.A. 301. 3. DEDUCTION - LOSSES - SALES TO CLOSELY OWNED CORPORATION. - A minority stockholder realized a deductible loss from the sale of securities to the corporation.
1Opinion of the Court
ESTATE OF A. C. O'LAUGHLIN, DECEASED, FIRST NATIONAL BANK OF CHICAGO AS EXECUTOR, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
O'Laughlin v. Commissioner
Docket Nos. 84319, 86966.
United States Board of Tax Appeals
38 B.T.A. 1120; 1938 BTA LEXIS 784;
November 9, 1938, Promulgated
1. TRUST REVOCABLE AFTER TAXABLE YEAR. - Section 166 of the Revenue Act of 1934 applies where the grantor retained the right to revoke the trust after the close of the year 1934.
2. TRUST INCOME - TAXABLE TO GRANTOR. - Income of trusts taxable to grantor who had extensive control over and benefit from…
2Cases cited3 opinions
- Wollman v. CommissionerUnited States Board of Tax Appeals · 1934
- Corning v. CommissionerUnited States Board of Tax Appeals · 1937
- O'Laughlin v. CommissionerUnited States Board of Tax Appeals · 1938