McCrory v. Commissioner of Internal Revenue

SIBLEY, Circuit Judge.

The main question on these cross-petitions is whether the income of a trust was wholly or partially distributable to the heneñeiaries during the tax year 1924 so as to entitle the trustee to a deduction from his taxable income. It is also questioned whether there was a trust rather than an irrevocable agency. Luke F. Wilson and Nellie M. Wilson were a man and wife of advanced years who had no descendants and desired to benefit their twenty-seven nieces and nephews, some of whom were also old and all more or less needy. On June 1.0, 1924, they executed the complicated…