RAND v. HELVERING

No. 11701.

116 F.2d 929 (1941)

RAND v. HELVERING, Commissioner of Internal Revenue.

Circuit Court of Appeals, Eighth Circuit.

January 13, 1941.


Attorney(s) appearing for the Case

Daniel N. Kirby, of St. Louis, Mo. (R. E. Blake, R. O. Rumer, and Harry W. Kroeger, all of St. Louis, Mo., on the brief), for petitioner.

Harry Marselli, Sp. Asst. to the Atty. Gen. (Samuel O. Clark, Jr., Asst. Atty. Gen., and Sewall Key and L. W. Post, Sp. Assts. to the Atty. Gen., on the brief), for respondent.

Before GARDNER, WOODROUGH, and JOHNSEN, Circuit Judges.


GARDNER, Circuit Judge.

This is a proceeding to review a decision of the Board of Tax Appeals which found a deficiency in the income of petitioner for the years 1934 and 1935. The Board held that the income of certain separate trusts created by the petitioner for the benefit of his children was, to the extent that it had been applied to the payment of premiums on life insurance, taxable income. The Board also held that the petitioner was not entitled to deduct from...

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