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BURNET v. WELLS

No. 792.

289 U.S. 670 (1933)

BURNET, COMMISSIONER OF INTERNAL REVENUE, v. WELLS.

Supreme Court of United States.

Decided May 29, 1933.

Attorney(s) appearing for the Case

Mr. Erwin N. Griswold, with whom Solicitor General Thacher, Miss Helen R. Carloss, and Mr. Sewall Key were on the brief, for petitioner.

Mr. J.S.Y. Ivins, with whom Messrs. Kingman Brewster, Percy W. Phillips, and Richard B. Barker were on the brief, for respondent.

MR. JUSTICE CARDOZO delivered the opinion of the Court.

Income of a trust has been reckoned by the taxing officers of the Government as income to be attributed to the creator of the trust in so far as it has been applied to the maintenance of insurance on his life. Section 219 (h) of the Revenue Acts of 1924 and 1926 permits this to be done. The question is whether as applied to...

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