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CARHART v. COMMISSIONER

Docket No. 6643.

5 T.C.M. 579 (1946)

Amory S. Carhart v. Commissioner.

United States Tax Court.

Entered June 20, 1946.

Attorney(s) appearing for the Case

Frank J. Wideman, Esq., 822 Connecticut Ave., N. W., Washington, D. C., for the petitioner. Walt Mandry, Esq., for the respondent.

Memorandum Opinion

OPPER, Judge:

By this proceeding petitioner seeks a redetermination of deficiencies in income tax for the years 1940 and 1941 in the amounts of $4,888.07 and $5,874.89, respectively.

The sole issue is whether the unexpended, accumulated income of two trusts for the benefit of petitioner's minor children is taxable to petitioner, grantor and co-trustee of the trusts, under section 22 (a) of the Internal Revenue Code.

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