Allen v. Commissioner

Glenn S. Allen, Sr. v. Commissioner.

Allen v. Commissioner

Docket No. 2149.

United States Tax Court

1944 Tax Ct. Memo LEXIS 395; 3 T.C.M. (CCH) 39; T.C.M. (RIA) 44014;

January 19, 1944

Charles H. Farrell, Esq., for the petitioner. Melvin S. Huffaker, Esq., for the respondent.

HARRON

Memorandum Findings of Fact and Opinion

HARRON, Judge: The respondent determined a deficiency of $9,148.44 in income tax for the year 1940. The only question for determination is whether petitioner, as grantor of a trust, is taxable on a dividend of $24,006.95 received by the trust after December 11, 1940, when the trust…