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COMMISSIONER OF INTERNAL REVENUE v. GROSVENOR

No. 411.

85 F.2d 2 (1936)

COMMISSIONER OF INTERNAL REVENUE v. GROSVENOR.

Circuit Court of Appeals, Second Circuit.

July 6, 1936.

Attorney(s) appearing for the Case

Robert H. Jackson, Asst. Atty. Gen. (Sewall Key and L. W. Post, Sp. Assts. to the Atty. Gen., of counsel), for petitioner.

George L. Shearer, of New York City (E. Sheldon Stewart, of New York City, of counsel), for respondent.

Before MANTON, SWAN, and CHASE, Circuit Judges.

SWAN, Circuit Judge.

The question presented by this litigation is whether the 1929 income of two trusts created by the taxpayer for the support of his two minor daughters constitutes taxable income to him.

In 1927 Theodore P. Grosvenor established two trusts, one for each of his two infant daughters. By the terms of each trust, the trustee was to pay the net income to the settlor's wife "to be expended by her for the support, maintenance and education" of...

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