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Helvering v. Clifford

United States Supreme Court
309 U.S. 331 (1940)


Facts

Clifford (plaintiff) created a trust consisting of securities for a term of five years. Clifford created the trust for his wife’s benefit, but the amount of trust income he paid to his wife over the five years was entirely in his discretion. Clifford exercised full control over the securities and maintained the power to use both the corpus of the trust and its income as he saw fit. Clifford stated that he created the trust in order to grant his wife a degree of security and independence, and not to evade taxes on the trust income. In 1934, Clifford issued all income generated by the trust to his wife, which she included as income for that year. However, the Commissioner (defendant) determined that the trust income remained taxable to Clifford. The Board of Tax Appeals found in favor of the Commissioner. The Court of Appeals reversed. The United States Supreme Court granted certiorari.

Rule of Law

Issue

Holding and Reasoning (Douglas, J.)

Dissent (Roberts, J.)

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