Legal Opinion

Howard v. Commissioner

United States Tax Court

Decided March 10, 1955No. Docket Nos. 41735, 41736Published

Father of petitioner created a trust on July 1, 1920, and conveyed to his wife, as trustee, his automobile business together with the property appurtenant thereto.

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Father of petitioner created a trust on July 1, 1920, and conveyed to his wife, as trustee, his automobile business together with the property appurtenant thereto. Under terms of trust indenture petitioner became entitled to receive one-fifth of the net income of the business accumulated between the time of the creation of the trust and the date he reached the age of 21. In December 1923, the trustee created a corporation and transferred to it the automobile business and its assets in exchange for all of its stock consisting of 15,000 shares. On March 31, 1925, petitioner reached the age of…

1Opinion of the Court

Lindsay C. Howard, Petitioner, v. Commissioner of Internal Revenue, Respondent. Lindsay C. Howard and Lucille K. Howard, Petitioners, v. Commissioner of Internal Revenue, Respondent

Howard v. Commissioner

Docket Nos. 41735, 41736

United States Tax Court

23 T.C. 962; 1955 U.S. Tax Ct. LEXIS 233;

March 10, 1955, Filed

Decisions will be entered under Rule 50.

Father of petitioner created a trust on July 1, 1920, and conveyed to his wife, as trustee, his automobile business together with the property appurtenant thereto. Under terms of trust indenture petitioner became entitled to receive one-fifth of…

2Cases cited9 opinions

  1. Helvering v. ReynoldsSupreme Court of the United States · 1941
  2. Maguire v. CommissionerSupreme Court of the United States · 1941
  3. Kenan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1940
  4. Archbold v. HelveringCourt of Appeals for the Second Circuit · 1940
  5. Brinckerhoff v. CommissionerUnited States Tax Court · 1947

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