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SENSENBRENNER v. COMMISSIONER OF INTERNAL REVENUE

No. 8097.

134 F.2d 883 (1943)

SENSENBRENNER v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Seventh Circuit.

April 8, 1943.

Attorney(s) appearing for the Case

Louis Quarles and Maxwell H. Herriott, both of Milwaukee, Wis., for petitioner.

Samuel O. Clark, Jr., Sewell Key, Samuel H. Levy, Arthur Manella, and Edward First, Asst. Attys. Gen., and J. P. Wenchel and John W. Smith, Bureau of Internal Revenue, both of Washington, D. C., for respondent.

Before EVANS, SPARKS, and MINTON, Circuit Judges.

SPARKS, Circuit Judge.

This petition to review a decision of the United States Tax Court presents a new phase of the question of the taxability under § 504(b) of the Revenue Act of 1932, 26 U.S.C.A. Int.Rev.Code, § 1003(b), relating to gift taxes, of gifts in trust, the income of which is immediately payable to certain named beneficiaries, but the corpus of which is not to be delivered to them until termination of the trust. The Tax Court held that each...

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