Frank v. Commissioner
United States Board of Tax Appeals
A transferred the bulk of his personal property to trustees under a deed of trust which made final disposition of the property upon termination of the trust, and reserved to himself power of revocation and right to direct trustees in sales and reinvestment of trust property. On the same day he executed a codicil to his will. The trust was not revoked; there is no evidence respecting control exercised by A over trust property.
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A transferred the bulk of his personal property to trustees under a deed of trust which made final disposition of the property upon termination of the trust, and reserved to himself power of revocation and right to direct trustees in sales and reinvestment of trust property. On the same day he executed a codicil to his will. The trust was not revoked; there is no evidence respecting control exercised by A over trust property. Upon A's death, his widow elected to take under the will, which left the entire estate to her. The value of the trust property was subjected to Federal estate and state…
1Opinion of the Court
OPINION.
GOODRICH:
In these proceedings, which were consolidated for hearing, petitioner asks for the redetermination of deficiencies in income taxes of $3,402.62 for 1928 and $4,182.42 for 1929, the greater part of which results from respondent’s action in including in her income for these years amounts of $29,678.42 and $42,926.56, respectively, paid to her by a trustee. As our findings of fact we adopt the statement agreed to at trial by counsel for the parties, together with the exhibits in evidence. For the purposes of this report the facts need not be recited in full.
Petitioner is the…
2Cases cited8 opinions
- Porter v. CommissionerSupreme Court of the United States · 1933
- Dolan's EstateSupreme Court of Pennsylvania · 1924
- Windolph v. Girard Trust Co.Supreme Court of Pennsylvania · 1914
- Houston's EstateSupreme Court of Pennsylvania · 1923
- Spangler's EstateSupreme Court of Pennsylvania · 1924
3 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Frank v. CommissionerUnited States Board of Tax Appeals · 1933