Irwin v. Gavit, 268 U.S. 161 (1925), was a case before the U.S. Supreme Court regarding the taxability, under United States tax law, of a divided interest in a bequest.

[1] It is notable (and thus appears frequently in law school casebooks)[2] for the following holding: Under Anthony N. Brady's will, a sixth of his estate would be held in trust for his granddaughter until she turned 21.

... " The Internal Revenue Code at the time provided that while the gains, profits and income "derived from any source whatsoever" was taxable, the value of property acquired by gift or bequest was not to be included in taxable income, and that trustees could be required to account for and withhold certain amounts for the payment of tax.

It seems to us hardly less clear that even if there were a specific provision that A should have no interest in the corpus, the payments would be income none the less, within the meaning of the statute and the Constitution, and by popular speech.

But we think that the provision of the act that exempts bequests assumes the gift of a corpus and contrasts it with the income arising from it, but was not intended to exempt income property so-called simply because of a severance between it and the principal fund.