EX PARTE POLLITT

Citator

Cited By (19 total)

• Helvering v. Leonard, 310 U.S. 80 (U.S. 1940)
  …nefit; see Old Colony Trust Co. v. Commissioner, 279 U. S. 716; United States v. Boston & Maine Railroad, 279 U. S. 732; or where the taxpayer creates a trust, the income of which is applied to the discharge of his debt. See Helvering v. Blumenthal, 296 U. S. 552. Here, as there, the taxpayer received a'benefit by the payments. The catalogue of benefits is not depleted when primary obligations are discharged. For these reasons that portion of the trust income which was received from the guaranteed bonds was…
• Commissioner OF Internal Revenue v. Makransky, 321 F.2d 598 (3d Cir. 1963)
  …e authorities cited by the trustees and find that in each case the distribution in question was made pursuant to discretionary power or mandatory directions expressly contained in the instrument creating the trust. See Helvering v. Blumenthal, 1935, 296 U.S. 552, 56 S.Ct. 305, 80 L.Ed. 390, reversing 2d Cir. 1935, 76 F. 2d 507 (trustee directed to apply income to payment of grantor’s debt); Douglas v. Willcuts, 1935, 296 U.S. 1, 3, 56 S.Ct. 59, 80 L.Ed. 3 (grantor and beneficiary stipulated [*604] that trus…
• Suhr v. Commissioner of Internal Revenue, 126 F.2d 283 (6th Cir. 1942)
  …of a trust created to discharge his legal obligations, and so used. Douglas v. Willcuts, supra; Helvering v. Stokes, 296 U.S. 551, 56 S.Ct. 308, 80 L.Ed. 389; Helvering v. Coxey, 297 U.S. 694, 56 S.Ct. 498, 80 L.Ed. 986, and Helvering v. Blumenthal, 296 U.S. 552, 56 S.Ct. 305, 80 L.Ed. 390. Where income is not used to discharge the grantor’s obligation, such income is not taxable to him. Stuart v. Commissioner, 7 Cir., 124 F. 2d 772. In the Grosvenor case it was assumed that the income there in question wa…