Longyear v. Commissioner

1. Petitioner and his divorced wife effected a settlement whereby petitioner, in lieu of alimony, delivered to the wife a note for $150,000 and agreed that a portion of his share of a trust created by his father's will should stand as security for the note. Held, that payments made to the wife in satisfaction of the note are taxable to petitioner as part of his distributive share of the trust estate. 2. Petitioner irrevocably assigned to trustees for the benefit of his children a portion of his interest in the trust created by his father's will. Held, that petitioner had divested himself of…