Laurence v. Kanter v. United States of America, Ruth Wolins v. United States of America, Jerome B. Kanter v. United States

^ Appellants sued in the district court to recover income taxes paid under deficiency assessments for the years 1945, 1946 and 1947. The rulings were wholly adverse to their contentions and they appeal.

The controversies arise out of three 15 year trusts established in 1944 by Minnie Kanter. Equal separate trusts were established for her three adult children: Laurence Y. Kanter, Jerome B. Kanter and Ruth Kanter Wolins. A sort of reciprocal arrangement of trustees, all members of the family, was established. Laurence’s trustees were his sister Ruth and her husband, Albert Wolins. Jerome’s trustees were Ruth and his brother Laurence. Ruth’s trustees were husband Albert and brother Laurence. Jerome was not a trustee and it is suggested the reason he was not was because he was away in the army. Income in each trust was to be accumulated in each trust for five year periods, then paid to be ben-efieiary.

The corpus of each trust initially was 6.81 per cent of the stock of Shop 'N Save, a Kanter family corporation organized under the laws of California. Mrs. Kanter carved the stock out of her 66.26 per cent stock ownership of Shop ’N Save, reducing her ownership to 45.83 per cent.…