This section contains the nature of the case and procedural background.

D owned an income interest in a trust for life. He assigned a portion of all of his future income from the trust to his children. A dispute erupted over who was responsible for the payment of taxes from the trust; the father or the children. The IRS wanted the father to pay. The Board of Tax Appeals ruled for the father and the Circuit Court of Appeals reversed. The Supreme Court granted certiorari.

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