Newman v. Commissioner
United States Tax Court
Petitioner's minor daughter and son were the respective life income beneficiaries of two trusts created by her during the tax year. Petitioner's husband, the trustee, was the remainderman and the donee of a power to appoint the remainders in the event he predeceased the life beneficiaries. He also possessed the power to alter, amend, or revoke.
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Petitioner's minor daughter and son were the respective life income beneficiaries of two trusts created by her during the tax year. Petitioner's husband, the trustee, was the remainderman and the donee of a power to appoint the remainders in the event he predeceased the life beneficiaries. He also possessed the power to alter, amend, or revoke. Held, the income of the trusts is not taxable to petitioner, under section 22 (a), 166, or 167 of the Internal Revenue Code, with the exception of dividends that had been declared payable to stockholders of record on or before June 28, 1940, the date…
1Opinion of the Court
Lillian M. Newman, Petitioner, v. Commissioner of Internal Revenue, Respondent
Newman v. Commissioner
Docket No. 109632
United States Tax Court
1 T.C. 921; 1943 U.S. Tax Ct. LEXIS 190;
April 13, 1943, Promulgated
Decision will be entered under Rule 50.
Petitioner's minor daughter and son were the respective life income beneficiaries of two trusts created by her during the tax year. Petitioner's husband, the trustee, was the remainderman and the donee of a power to appoint the remainders in the event he predeceased the life beneficiaries. He also possessed the power to alter, amend, or revoke. Held,…
Also in this document: Dissent.
2Cases cited13 opinions
- Helvering v. CliffordSupreme Court of the United States · 1940
- Helvering v. HorstSupreme Court of the United States · 1940
- Helvering v. StuartSupreme Court of the United States · 1942
- Douglas v. WillcutsSupreme Court of the United States · 1935
- Carrier v. . CarrierNew York Court of Appeals · 1919
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