Opinion
No. 10508.
June 4, 1948.
Petition to review decision of the Tax Court.
Petition by Leslie H. Green to review a decision of the Tax Court redetermining a deficiency in income taxes assessed by the Commissioner of Internal Revenue.
Decision affirmed.
Raphael M. O'Hara and Benjamin E. Jaffe, both of Detroit, Mich. for petitioner.
Charles Oliphant, J.P. Wenchel, and Sewall Key, all of Washington, D.C., for respondent.
Before HICKS, ALLEN and MARTIN, Circuit Judges.
This case came on to be heard on the record and briefs and oral argument of counsel.
And it appearing that the petitioner created two trusts for the benefit of his wife and minor son respectively, under which, as settlor-trustee, petitioner retained broad managerial powers over the trust, including the right to deal with himself as an individual with respect to the trust properties, which right he exercised extensively;
And it appearing that the decision of the Tax Court holding the petitioner taxable as an individual on the income of such trusts is correct; Helvering v. Clifford, 309 U.S. 331, 60 S.Ct. 554, 84 L.Ed. 788; Miller v. Commissioner, 6 Cir., 147 F.2d 189, 193; Shapero v. Commissioner, 6 Cir., 165 F.2d 811, 813, 814;
And no reversible error appearing in the record:
It is ordered that the decision of the Tax Court be, and it hereby is affirmed.