Security First Nat'l Bank v. Commissioner
United States Board of Tax Appeals
1. Where a grantor created a trust but retained during his life absolute dominion over the personal property and the rents, issues, and profits of both real and personal property of the trust, the income of the trust for 1925, 1926, and the period in 1927 up to the date of the death of the grantor, must be included in computing the net income of the grantor. 2. Ranch held operated for profit rather than merely for pleasure of a wealthy man. 3. Where a corporation, at the…
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1. Where a grantor created a trust but retained during his life absolute dominion over the personal property and the rents, issues, and profits of both real and personal property of the trust, the income of the trust for 1925, 1926, and the period in 1927 up to the date of the death of the grantor, must be included in computing the net income of the grantor. 2. Ranch held operated for profit rather than merely for pleasure of a wealthy man. 3. Where a corporation, at the suggestion of and in order to accommodate its sole stockholder, transfers some of its assets so that art objects which the…
1Opinion of the Court
*305OPINION.
I
Murdock:
The Commissioner has included in the decedent’s income for each period the income for the corresponding period of the trust, known as the Henry E. Huntington Library and Art Gallery. The explanation given in the notice of deficiency and the arguments now advanced by the -respondent indicate that he relies *306upon the following provisions of subsections (g) and (h) of section 219 of the Revenue Act of 1926:(g) Where the grantor of a trust has, at any time during the taxable year, * * * the power to revest in himself title to any part of the corpus of the trust, then the income of…
2Cases cited41 opinions
- Corliss v. BowersSupreme Court of the United States · 1930
- Lucas v. American Code Co.Supreme Court of the United States · 1930
- Crooks v. HarrelsonSupreme Court of the United States · 1930
- Tyler v. United StatesSupreme Court of the United States · 1930
- Burnet v. ClarkSupreme Court of the United States · 1932
36 more not listed; retrieve them via the Exa API.
3Cited by30 opinions
- Edgar v. CommissionerUnited States Tax Court · 1971
- Abraham Teitelbaum v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1961
- Christensen v. CommissionerUnited States Tax Court · 1963
- Hamilton National Bank of Chattanooga v. CommissionerUnited States Board of Tax Appeals · 1933
- Drawoh, Inc. v. CommissionerUnited States Board of Tax Appeals · 1933
25 more not listed; retrieve them via the Exa API.