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ESTATE OF SANFORD v. COMM'R.

No. 34.

308 U.S. 39 (1939)

ESTATE OF SANFORD v. COMMISSIONER OF INTERNAL REVENUE.

Supreme Court of United States.

Decided November 6, 1939.

Attorney(s) appearing for the Case

Mr. Montgomery B. Angell, with whom Messrs. John W. Davis, Otis T. Bradley, William A. Carr, and Marvin Lyons were on the brief, for petitioner.

Miss Helen R. Carloss, with whom Solicitor General Jackson, Assistant Attorney General Clark, and Messrs. Sewall Key, J. Louis Monarch, and Richard H. Demuth were on the brief, for respondent.

By leave of Court, Messrs. Beverley R. Robinson, E.N. Perkins, and Weston Vernon, Jr. filed a brief, as amici curiae, urging reversal.

MR. JUSTICE STONE delivered the opinion of the Court.

This and its companion case, Rasquin v. Humphreys, post, p. 54, present the single question of statutory construction whether in the case of an inter vivos transfer of property in trust, by a donor reserving to himself the power to designate new beneficiaries other than himself, the gift becomes complete and subject to the gift tax imposed by the federal...

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