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Corliss v. Bowers

Citation. Corliss v. Bowers, 281 U.S. 376, 50 S. Ct. 336, 74 L. Ed. 916, 2 U.S. Tax Cas. (CCH) P525, 8 A.F.T.R. (P-H) 10910, 1930-1 C.B. 254, 1930 P.H. P958 (U.S. Apr. 28, 1930)
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Brief Fact Summary.

Petitioner created a trust for his wife and children. He retained the power to revoke the trust at any time. At issue was whether or not he had to claim the income from the trust as his gross income.

Synopsis of Rule of Law.

When the grantor of a trust has the power to take full ownership of any part of the corpus of the trust, then the income should be considered as grantor’s.


Petitioner transferred a fund to trustees for them to pay the income to his wife for life and the remainder to his children. Petitioner, however, retained full power and control of the trust because it could be revoked at any time. The income for the year 1924 was paid to his wife, and Petitioner argues that it should not be counted as his.


Should the trust income be considered Petitioner’s income?


Justice Holmes issued the opinion for the Supreme Court of the United States in holding that income should be considered Petitioner’s.


The Supreme Court found that even though Petitioner transferred the income to his wife he still maintained control of all aspects of the trust. He could at any time revoke the trust and take control of the income.

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