property upon its sale, and that the Salvatore children were not sellers but mere "conduits." Other relevant cases In Helvering v. Horst, the United States Supreme Court held: that transfers of the rights to income may not be effective in shifting the tax burden to the recipient of that income In Estate of Stranahan v. Commissioner, the United States Court of Appeals for the Sixth Circuit addressed the situation where the income rights are sold instead of gifted. References External links United States taxation and revenue case law United States Tax Court cases Texaco 1970 in United States case law