United States Tax Court February 27, 1946, Docket Nos. 4382, 4383 (Chertoff v. Commissioner)

lead-opinion

OPINION.

Hill, Judge:

The first issue is whether the petitioners are taxable on the income of the trusts created by them in 1937 and 1940. If respondent is correct in his contention that the petitioners are so taxable, we need not consider whether they are likewise so taxable in 1940 and 1941 under the partnership aspects of the case.