TRUST OF SMYTH v. COMMISSIONER

Docket Nos. 110422, 110423, 110424, 110425.

1 T.C.M. 1019 (1943)

Trust of Robert Walsh Smyth, John M. Smyth, Ethel Walsh Smyth, and John M. Smyth, Jr., Trustees v. Commissioner. Trust of John M. Smyth, Jr., John M. Smyth, Ethel Walsh Smyth, and John M. Smyth, Jr., Trustees v. Commissioner. Trust of Barbara Jane Smyth, John M. Smyth, Ethel Walsh Smyth, and John M. Smyth, Jr., Trustees v. Commissioner. Trust of Nelson Edward Smyth, John M. Smyth, Ethel Walsh Smyth, and John M. Smyth, Jr., Trustees v. Commissioner.

United States Tax Court.

Entered May 5, 1943.


Attorney(s) appearing for the Case

John E. Hughes, Esq., for the petitioners. G. E. Gibson, Esq., for the respondent.


Memorandum Findings of Fact and Opinion

LEECH, Judge:

Respondent has determined a liability of $600 against each of the petitioners as a "transferee or donee" of John M. Smyth and as representing an unpaid gift tax deficiency of the latter for the year 1937. The question in each proceeding is the same and they are consolidated for hearing.

Findings of Fact

The petitioners are four trusts created on December 30, 1937 by John M. Smyth through...

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