RIDDICK, Circuit Judge.
This is an appeal from a judgment against a taxpayer in a suit to recover an alleged overpayment of income taxes for the year 1919. The facts are not in dispute. The question presented is whether the taxpayer is liable for income taxes upon that part of the income of a trust, payable to him as beneficiary, which the trustees paid over to taxpayer's mother at his direction.
William McMillan died in 1901, leaving his estate in trust,...
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