Dravo v. Commissioner
United States Board of Tax Appeals
1. REVENUE ACT OF 1928, SECTION 167. - Where, under the terms of a trust, its income could be accumulated, added to corpus and the income, only, on that aggregate corpus was distributable to the grantor of the trust, upon his wife's death, held, that original accumulated trust income, added to and becoming part of the corpus, is not taxable to the grantor of the trust under the above statutory provision.
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1. REVENUE ACT OF 1928, SECTION 167. - Where, under the terms of a trust, its income could be accumulated, added to corpus and the income, only, on that aggregate corpus was distributable to the grantor of the trust, upon his wife's death, held, that original accumulated trust income, added to and becoming part of the corpus, is not taxable to the grantor of the trust under the above statutory provision. Preston R. Bassett,33 B.T.A. 182; Arthur J. Morris,33 B.T.A. 241. 2. Id. - Where, under such express trust or a resulting trust arising upon a grantor-controlled failure of the express trust,…
1Opinion of the Court
FANNY M. DRAVO AND FIDELITY TRUST COMPANY, SURVIVING EXECUTORS OF THE WILL OF FRANCIS R. DRAVO, DECEASED, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Dravo v. Commissioner
Docket No. 78375.
United States Board of Tax Appeals
34 B.T.A. 190; 1936 BTA LEXIS 735;
March 24, 1936, Promulgated
1. REVENUE ACT OF 1928, SECTION 167. - Where, under the terms of a trust, its income could be accumulated, added to corpus and the income, only, on that aggregate corpus was distributable to the grantor of the trust, upon his wife's death, held, that original accumulated trust income, added to and…
2Cases cited4 opinions
- Bassett v. CommissionerUnited States Board of Tax Appeals · 1935
- Dravo v. CommissionerUnited States Board of Tax Appeals · 1936
- Kaplan v. CommissionerUnited States Board of Tax Appeals · 1932
- Morris v. CommissionerUnited States Board of Tax Appeals · 1935