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HELVERING v. HUTCHINGS

No. 419.

312 U.S. 393 (1941)

HELVERING, COMMISSIONER OF INTERNAL REVENUE, v. HUTCHINGS.

Supreme Court of United States.

Decided March 3, 1941.

Attorney(s) appearing for the Case

Solicitor General Biddle, with whom Assistant Attorney General Clark and Messrs. Sewall Key and Thomas E. Harris were on the brief, for petitioner.

Messrs. Rupert R. Harkrider and T.W. Lain for respondent.

MR. JUSTICE STONE delivered the opinion of the Court.

The petition for certiorari presents the single question whether under § 504 (b) of the Revenue Act of 1932, 47 Stat. 169, 247, the donor of property in trust for the benefit of numerous beneficiaries is entitled to a single gift tax exemption or exclusion to the extent of the first $5,000 or to separate exemptions of $5,000 for each beneficiary.

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