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