United States Board of Tax Appeals December 2, 1941, Docket Nos. 102775, 102776, 102777 (Pettus v. Commissioner)

*859OPINION.

Leech::

As to the petitioner, James ÍT. Pettus, respondent contends that he is taxable under section 167 of the Eevenue Act of 19361 upon the 1936 income of two trusts evidenced by trust agreements executed by him on November 10, 1933. In the alternative he contends that the petitioner, May W.