Hallowell v. Commissioner

BIGGS, Circuit Judge.

On September 27, 1937 the taxpayer’s; husband established an irrevocable trust (“No. 2 Trust”) to which he conveyed certain-stocks, naming his son as trustee. The-second paragraph of the indenture provided', that, “The said Trustee shall hold said, shares of stock and any stock dividends, paid thereon intact during the natural life-of my wife, Blanche N. Hallowell, and collect the net income thereof. Within thirty-days after the expiration of any fiscal year the beneficiary shall notify the Trustee in. writing if she desires the income collected, *537during the past fiscal…