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HOLDEEN v. UNITED STATES

186 F.Supp. 75 (1958)

Jonathan HOLDEEN, Plaintiff, v. UNITED STATES of America, Defendant.

United States District Court S. D. New York.

December 17, 1958.

Attorney(s) appearing for the Case

Jonathan Holdeen pro se.

Arthur H. Christy, U. S. Atty., New York City, Robert J. Ward, Asst. U. S. Atty., New York City, of counsel, for defendant.

WEINFELD, District Judge.

The plaintiff is the grantor under three (3) separate trusts. The Commissioner of Internal Revenue determined that the trust income for the year 1946 was taxable to the plaintiff who now moves for summary judgment to recover the payments made by him following the Commissioner's deficiency assessment. Whether the grantor did any act or thing which reflected ownership or reservation of control over the corpus or the income of the trust is an...

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