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REID TRUST v. COMMISSIONER

Docket No. 5132.

6 T.C. 438 (1946)

JAMES S. REID TRUST, CENTRAL NATIONAL BANK OF CLEVELAND AND FELICE C. REID, TRUSTEES, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated March 11, 1946.

Attorney(s) appearing for the Case

Mark A. Loofbourrow, Esq., for the petitioners.

Thos. F. Callahan, Esq., for the respondent.

OPINION.

DISNEY, Judge:

This case involves income tax liability for the years 1941 and 1942, as to which deficiencies were determined by the Commissioner in the amounts of $3,536.33 and $2,119.32, respectively. The single question presented is whether or not a certain instrument provided for only one trust for three children, or three trusts, one for each child. The petitioner contends first that in fact the instrument provided for three trusts and...

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