James Clark McReynolds

“ The trustees, claiming, among other things, the right to keep possession of the accumulations of such income until Catherine should become of age, when they conceded she would be entitled to the corpus as well as all accumulated income, declined to comply with that demand. Thereupon suit was brought in the name of the minor, by her father as next friend, in the federal court for the district in West Virginia in which the testator was residing at the time of his death, against the trustees to compel distribution of the income involved in accordance with the guardian's previous demand. ”

“ Commissioner v. Field (C.C.A.) 42 F. (2d) 820; Hutchings v. Burnet, 61 App.D.C. 109, 58 F. (2d) 514; Walker v. Commissioner (C.C.A.) 63 F. (2d) 351; Lindley v. Commissioner (C.C.A.) 63 F. (2d) 807. Moreover, guardianship is not recognized by the statute as a taxable entity. ”