United States Tax Court September 27, 1946, Docket Nos. 5243, 5244 (Funk v. Commissioner)

lead-opinion

OPINION.

HaRROn, Judge:

The issue in this case is whether petitioner is taxable under section 22 (a) of the Revenue Act of 1938 and the Internal Revenue Code on the income of trusts A, B, C, and D. Petitioner was not the grantor of the trusts. Her husband was. Moreover, he retained the power to dispose of the corpus by will when the trusts terminated upon his death.