JACOBS v. COMMISSIONER OF INTERNAL REVENUE

No. 10198.

129 F.2d 99 (1942)

JACOBS v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Fifth Circuit.

June 26, 1942.


Attorney(s) appearing for the Case

Maurice Jacobs, of Miami, Fla., in pro. per.

Joseph M. Jones, Sewall Key, J. Louis Monarch, and L. W. Post, Sp. Assts. to Atty. Gen., Samuel O. Clark, Jr., Asst. Atty. Gen., and J. P. Wenchel, Chief Counsel, Bureau of Internal Revenue, and Rollin H. Transue, Sp. Atty., Bureau of Internal Revenue, both of Washington, D. C., for appellee.

Before SIBLEY, HUTCHESON, and HOLMES, Circuit Judges.


HOLMES, Circuit Judge.

This is a petition to review an order of the Board of Tax Appeals sustaining a determination of the Commissioner that petitioner, as settlor of the Jacobs Trust, was taxable upon the entire trust income for the years 1935, 1936, and 1937. The question is whether the record contains substantial evidence to support the Board's finding that the settlor retained such dominion and control over the property transferred as would entitle the Commissioner...

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