Ketcham v. Commissioner

OPINION.

SteRnhagen, Judge:

1. — In the deficiency notices the “explanation” is that the income received by the petitioner from the Francis V. duPont trusts in excess of the amount expended for the maintenance of the children is taxable to her. So much of the trust income as was expended for the children is admitted by the Commissioner not to be within this petitioner’s income, and is therefore not in controversy. The amount for each year is shown in the schedule of the findings.

The trusts were established- in 1931 in contemplation of divorce. The 1933 income of the second trust had been…