Harrison v. Schaffner
United States Supreme Court
312 U.S. 579 (1941)
- Written by Kelsey Libby, JD
Facts
The life beneficiary of a trust (beneficiary) (plaintiff) sought to assign certain amounts of trust income to others without paying income tax on them. In December 1929, the beneficiary assigned specified amounts from the trust income to her children for the following calendar year. In November 1930, the beneficiary did the same thing. The trustees paid the children the specified amounts directly. The commissioner of internal revenue (defendant) determined that the assigned income was taxable to the beneficiary and assessed a deficiency against her as a result. On appeal, the district court held that the assigned income was not taxable to the beneficiary, and the court of appeals affirmed. The commissioner appealed.
Rule of Law
Issue
Holding and Reasoning (Stone, J.)
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