Vanderbilt Law Review


Robert Doty

First Page



A progressive income tax structure encourages the taxpayer with income above his consumption level to attempt to shift income to other members of his family group where it would be taxed at lower rates. The income which the taxpayer desires to shift may be in the form of compensation for services rendered by the taxpayer or of income from income-producing property owned by him...This article seeks to explore the extent to which the benefits of the short-term trust can be secured for this latter class of persons by utilizing business assets as trust corpus in the following manner: (1) by transferring to the trust specific assets which are leased back by the grantor for continued use in his business; or (2) by transferring to the trust a partnership interest in the grantor's business.