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PILLSBURY v. BURNET

No. 5407.

67 F.2d 151 (1933)

PILLSBURY v. BURNET, Commissioner of Internal Revenue.

Court of Appeals of the District of Columbia.

Decided June 12, 1933.

Rehearing Denied October 10, 1933.

Attorney(s) appearing for the Case

James S. Y. Ivins and Richard B. Barker, both of Washington, D. C., for appellant.

G. A. Youngquist, M. K. Rothschild, C. M. Charest, DeWitt M. Evans, and Sewall Key, all of Washington, D. C., for appellee.

Before MARTIN, Chief Justice, and ROBB, VAN ORSDEL, HITZ, and GRONER, Associate Justices.

MARTIN, Chief Justice.

This appeal involves income taxes for the years 1924 and 1925 respectively.

The case arises under section 219 (h) of the Revenue Acts of 1924 and 1926 (26 USCA § 960 note), the pertinent part of which reads as follows: "Where any part of the income of a trust is or may be applied to the payment of premiums upon policies on insurance on the life of the grantor * * * such part of the income of the trust shall be included in computing...

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