LITTEL v. COMMISSIONER OF INTERNAL REVENUE

No. 120.

154 F.2d 922 (1946)

LITTEL v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Second Circuit.

April 9, 1946.


Attorney(s) appearing for the Case

John A. Gage, of Washington, D. C., for petitioner.

Newton K. Fox, of Washington, D. C., for respondent.

Before L. HAND, SWAN and PHILLIPS, Circuit Judges.


L. HAND, Circuit Judge.

This case involves deficiencies in income tax for the years 1939, 1940 and 1941. The question is whether the income arising from three trusts created by the taxpayer on January 2, 1937, should be included in the income of the trusts, or in that of the grantor. The trusts were all alike and need not be separately considered. The trustees were the grantor, his mother, and a bank; and the declared purpose was to set up each fund in order to enable...

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