Supreme Court of the United States
Harrison v. Schaffner
March 31, 1941312 U.S. 579
Summary
The Supreme Court held that income assigned by a trust beneficiary to others is taxable to the assignor, not the assignees, under the 1928 Revenue Act. The Court reversed the lower courts, emphasizing that the power to dispose of income is equivalent to ownership and that anticipatory assignments constitute realization of income.
Holding
- Whether income assigned by a trust beneficiary to others is taxable to the assignor or to the assignees under the 1928 Revenue Act.. The assigned income is taxable to the assignor (donor) and not to the assignees.
Docket 437
Cited authorities
- 45 Stat. 791
Cited by
- The National Shawmut Bank of Boston & another, trustees v. Minnie B. Joy & others
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- Paul A. Teschner and Barbara M. Teschner v. Commissioner of Internal Revenue
- J. Leonard Schmitz and Alice Schmitz v. Commissioner of Internal Revenue, Respondent Albert H. Throndson and Doris…
- J. Leonard Schmitz and Alice Schmitz v. Commissioner of Internal Revenue, Respondent Albert H. Throndson and Doris…
- Camiel Thorrez v. Commissioner of Internal Revenue, Joseph Michner v. Commissioner of Internal Revenue, Walter…