Myer v. Commissioner
United States Tax Court
Petitioner was the settlor-trustee of a trust created for the benefit of her son. As trustee she had broad managerial powers and the right to distribute or accumulate the income until the beneficiary reached the age of 30 years, at which time the accumulated income as well as the corpus of the trust was distributable to him. Held, no part of the income of the trust is taxable to petitioner under section 22 (a), Internal Revenue Code.
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Petitioner was the settlor-trustee of a trust created for the benefit of her son. As trustee she had broad managerial powers and the right to distribute or accumulate the income until the beneficiary reached the age of 30 years, at which time the accumulated income as well as the corpus of the trust was distributable to him. Held, no part of the income of the trust is taxable to petitioner under section 22 (a), Internal Revenue Code. J. M. Leonard, 4 T. C. 1271, and cases cited therein.
1Opinion of the Court
OPINION.
Arundell, iJv¡dge\
The petitioner asserts error on the part of the respondent in attributing to her, under section 22 (a) of the Internal Revenue Code, that portion of the trust income derived from property placed in the trust by her. She contends that her gifts were complete and that even though she was trustee with wide management powers, she had no taxable interest whatsoever in the corpus or the income thereof and that she enjoyed no economic advantages as a result of her trusteeship. The respondent, in support of his determination, relies principally upon Joel E. Hall, 4 T. C.…
2Cases cited6 opinions
- Helvering v. CliffordSupreme Court of the United States · 1940
- Cartinhour v. CommissionerUnited States Tax Court · 1944
- Lowenstein v. CommissionerUnited States Tax Court · 1944
- Hall v. CommissionerUnited States Tax Court · 1944
- Cherry v. CommissionerUnited States Tax Court · 1944
1 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Myer v. CommissionerUnited States Tax Court · 1946