Legal Opinion

Garland v. Commissioner

United States Tax Court

Decided July 2, 1943No. Docket No. 109902Unpublished

The income of a trust created by petitioner consisted of taxable and tax-exempt income. Held, the trust income during the tax years that was (1) received by petitioner, (2) used to pay premiums upon insurance policies covering his life, and (3) used for the support of his minor children, is taxable to petitioner in the same ratio that the taxable income of the trust bears to the total net income of the trust.

1Opinion of the Court

William J. Garland, Deceased, by Harry C. Mabry, Executor of the Estate of William J. Garland, Deceased, and Grace O. Garland v. Commissioner.

Garland v. Commissioner

Docket No. 109902.

United States Tax Court

1943 Tax Ct. Memo LEXIS 213; 2 T.C.M. (CCH) 419; T.C.M. (RIA) 43339;

July 2, 1943

The income of a trust created by petitioner consisted of taxable and tax-exempt income. Held, the trust income during the tax years that was (1) received by petitioner, (2) used to pay premiums upon insurance policies covering his life, and (3) used for the support of his minor children, is taxable to petitioner…

2Cases cited5 opinions

  1. Burnet v. WellsSupreme Court of the United States · 1933
  2. Coffey v. CommissionerUnited States Tax Court · 1943
  3. Rathborne v. CommissionerUnited States Board of Tax Appeals · 1938
  4. Rosenzweig v. CommissionerUnited States Tax Court · 1942
  5. Letts v. CommissionerUnited States Board of Tax Appeals · 1940

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