COMMISSIONER OF INTERNAL REVENUE v. GOULDER

No. 8625.

123 F.2d 686 (1941)

COMMISSIONER OF INTERNAL REVENUE v. GOULDER.

Circuit Court of Appeals, Sixth Circuit.

December 2, 1941.


Attorney(s) appearing for the Case

Newton K. Fox, Sp. Asst. to Atty. Gen. (Samuel O. Clark, Jr., Asst. Atty. Gen., and J. Louis Monarch, Helen R. Carloss, and L. W. Post, Sp. Assts. to Atty. Gen., on the brief), for petitioner.

Isador Grossman, of Cleveland, Ohio (McAfee, Grossman, Hanning & Newcomer, Isador Grossman, and Ralph A. Colbert, all of Cleveland, Ohio, on the brief), for respondent.

Before SIMONS, HAMILTON and MARTIN, Circuit Judges.


HAMILTON, Circuit Judge.

Respondent, Herbert G. Goulder, was the owner of 5,000 shares of the common capital stock of the Federal Knitting Mills Company. On October 1, 1934, he executed a trust instrument transferring the entire 5,000 shares to himself as trustee for the benefit of his wife, Edna G. Goulder, and caused the corporation to so transfer the shares on its books. The preamble to the declaration of trust provided...

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