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RASQUIN v. HUMPHREYS

No. 37.

308 U.S. 54 (1939)

RASQUIN, COLLECTOR OF INTERNAL REVENUE, v. HUMPHREYS.

Supreme Court of United States.

Decided November 6, 1939.

Attorney(s) appearing for the Case

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 petitioner.

Mr. Sidney W. Davidson, with whom Mr. Allin H. Pierce was on the brief, for respondent.

MR. JUSTICE STONE delivered the opinion of the Court.

Decision in this case turns on the question, differing only in form from that this day decided in Sanford v. Helvering, ante, p. 39, whether, in case of an inter vivos transfer of property in trust, reserving to the donor power to designate new beneficiaries other than himself, the gift becomes complete at the time of the creation of the trust and subject to the gift tax imposed by the Revenue...

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