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ESTATE OF WELLS v. COMMISSIONER

Docket No. 110674.

2 T.C.M. 446 (1943)

Estate of Caroline C. Wells, Deceased, by Edward D. Stannard, Henry H. Wells, and Frank Wells McCabe, Executors v. Commissioner.

United States Tax Court.

Entered July 10, 1943.

Attorney(s) appearing for the Case

Robert C. Poskanzer, Esq., for the petitioner. Walt Mandry, Esq., for the respondent.

Memorandum Opinion

LEECH, Judge:

Respondent has determined a deficiency in gift tax of the decedent, Caroline C. Wells, for the year 1938 in the sum of $3,058.49. The issue is whether a transfer in trust by decedent in 1938 for the benefit of six grandchildren constituted gifts of future or present interests in property.

[The Facts]

We find the facts as stipulated. Briefly these are...

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