Court of Appeals for the Second Circuit July 9, 1941, 239 (Richardson v. Commissioner of Internal Revenue)

AUGUSTUS N. HAND, Circuit Judge.

This is an appeal by H. S. Richardson from a decision of the Board of Tax Appeals adjudging an income tax deficiency against him of $199,920.36 for the year 1933. Two questions are involved. The first is whether the income for the year 1933 from five trusts created by the taxpayer’s wife in May, 1932, is taxable against him.