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ESTATE OF MORGAN v. COMMISSIONER

Docket No. 1770.

3 T.C.M. 1156 (1944)

Estate of J. P. Morgan, Deceased, Junius S. Morgan, Henry S. Morgan and J. P. Morgan & Co., Incorporated, Executors v. Commissioner.

United States Tax Court.

Entered October 30, 1944.

Attorney(s) appearing for the Case

Montgomery B. Angell, Esq., and George Craven, Esq., 15 Broad St., New York, N. Y., for the petitioners. Conway Kitchen, Esq., for the respondent.

Memorandum Opinion

SMITH, Judge:

This proceeding is for the redetermination of a deficiency in income tax of J. P. Morgan, deceased, for 1937 in the amount of $241,654.32. The proceeding presents the following issues:

(1) Did the entire net income amounting to $120,276.08, which was derived during the calendar year 1937 from a trust created by the decedent on February 7, 1930, constitute taxable income to him for that year?

(2) Was the decedent...

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