Commissioner of Internal Revenue v. Katz

MAJOR, Circuit Judge.

This is an appeal by the Commissioner of Internal Revenue from a decision of the Board of Tax Appeals (Tax Court of the United States), finding no deficiency in respondents’ income taxes for the year 1937.

On April 5,- 1937,, Meyer Katz executed four separate written declarations of trust, one each for the-benefit of his wife, Helen Katz, and their three children, all of whom were minors during the taxable year, except one who became of age during such year. The trust for the benefit of his wife is not involved in this litigation. The provisions of the trust instruments…