Corliss v. Bowers

Corliss (plaintiff) created a trust naming his wife as lifetime income beneficiary and their children as remainder beneficiaries, but reserved for himself the right to terminate or modify the trust at any time; although trust income was actually paid to his wife during the relevant tax year, the government taxed that income to Corliss himself, and he sued for a refund after paying, arguing the trustee held legal title and his wife held equitable title, making the income hers for tax purposes.