Helvering v. Achelis

The Commissioner appeals from an order of the Board of Tax Appeals expunging a deficiency in income taxes assessed by him against the taxpayer for the years 1934 and 1935. On April 5, 1932, the taxpayer transferred some securities to two persons in trust to be held by them xxntil December 31, 1937, or until her death if she died before that day; in December, 1934, she extended the possible duration of this trust to December 31, 1939. The trustees were to collect the income and pay it— after deducting necessary expenses — to a New York educational corporation. During the period of the trust…