SMITH v. COMMISSIONER OF INTERNAL REVENUE

No. 12322.

131 F.2d 254 (1942)

SMITH v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Eighth Circuit.

Rehearing Denied December 23, 1942.


Attorney(s) appearing for the Case

Elmer B. Hodges, of Kansas City, Mo. (Albert F. Hillix and Gage, Hillix, Hodges & Cowherd, all of Kansas City, Mo., on the brief), for petitioner.

Bernard Chertcoff, Sp. Asst. to the Atty. Gen. (Samuel O. Clark, Jr., Asst. Atty. Gen., and Sewall Key and J. Louis Monarch, Sp. Assts. to the Atty. Gen., on the brief), for respondent.

Before GARDNER, WOODROUGH, and RIDDICK, Circuit Judges.


RIDDICK, Circuit Judge.

This is a petition for review of a decision of the United States Board of Tax Appeals, the single question presented being whether certain transfers in trust made by the petitioner for the benefit of her four minor grandchildren were gifts of present or future interests under § 504(b) of the Revenue Act of 1932, 47 Stat. 247, 26 U. S.C.A. Int.Rev.Acts page 585. The petitioner contends that in computing her 1937 gift tax, she is entitled...

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