Friedman v. Comm'r of Internal Revenue

3 Citing cases

  1. Richards v. Comm'r of Internal Revenue

    19 T.C. 366 (U.S.T.C. 1952)   Cited 2 times

    As he was the president of each corporation, both before and after the trusts were created, the voting rights which he retained could be used to advance or benefit his own economic interest, particularly in maintaining the aggregate salary, in the amount of close to $600 per week, payable to himself, as president, and to one person serving directly under him, the maximum provided in the November 22, 1934, agreement. Cf. Helvering v. Clifford, supra; M. Friedman, 7 T.C. 54; Lillian R. Chertoff, 6 T.C. 266, affd. 160 F.2d 691. The right to vote stock has been regarded as one of the major rights of ownership entitled to considerable weight.

  2. Welch v. Comm'r of Internal Revenue

    8 T.C. 1139 (U.S.T.C. 1947)   Cited 2 times

    The amendments specifically applied to the income of the respective trusts for each calendar year and, since these amendments were executed December 23, 1941, they operated on the income received on June 30, 1941, during the taxable year, and we think they are effective and material to the issues herein. Is the income of the four trusts created by the petitioner taxable to him under section 22(a) of the Internal Revenue Code? Respondent relies principally upon Helvering v. Clifford, 309 U.S. 331; Louis Stockstrom, 3 T.C. 255; affd., 148 Fed.(2d) 491; certiorari denied, 326 U.S. 719; M. Friedman, 7 T.C. 54; Leslie H. Green, 7 T.C. 263; and Anna Morgan, 5 T.C. 1089. Petitioner contends that the income of the four trusts is not taxable to him under the doctrine of the Clifford case.

  3. Shapero v. Comm'r of Internal Revenue

    8 T.C. 104 (U.S.T.C. 1947)   Cited 1 times

    Whether a settlor-trustee's power to distribute or accumulate income for some specified number of years, coupled with broad powers to manage the corpus, the be sufficient in itself to invoke the Clifford rule, we need not here determine. See Leslie H. Green, supra; M. Friedman, 7 T.C. 54; and Lillian R. Chertoff, 6 T.C. 266, and compare with Hall v. Commissioner, 150 Fed.(2d) 304, reversing 4 T.C. 506; David L. Loew, supra; W. L. Taylor, 6 T.C. 201, and Alma M. Myer, supra. We do think that the retention of such a power may and did here make possible the settlor's continued economic benefit from the income of the property formally dedicated to the trust.