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

In 1922, Corliss (P) transferred a fund in trust to pay the income to his wife for life with remainder over to the children. P reserved the power to modify the instrument creating the trust and to revoke in whole or part the indenture and or trust. Under the Code, the statute provides that when the grantor of a trust has at any time during the taxable year retained the power to revest in himself the corpus of the trust then the income of such part of the trust for that taxable year should be attributable to him. The net income in 1924 was paid over to P's wife, and because the income was never his, P claims that he cannot be taxed for it. Both courts below ruled against P. The Supreme Court granted certiorari.

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