SMITH v. SHAUGHNESSY

No. 429.

318 U.S. 176 (1943)

SMITH v. SHAUGHNESSY, COLLECTOR OF INTERNAL REVENUE.

Supreme Court of United States.

Decided February 15, 1943.


Attorney(s) appearing for the Case

Mr. Ellsworth C. Alvord, with whom Messrs. Floyd F. Toomey, John H. Hughes, and Willis H. Michell were on the brief, for petitioner.

Mr. Arnold Raum, with whom Solicitor General Fahy, Assistant Attorney General Clark, and Messrs. Sewall Key, J. Louis Monarch, and L.W. Post were on the brief, for respondent.


MR. JUSTICE BLACK delivered the opinion of the Court.

The question here is the extent of the petitioner's liability for a tax under §§ 501, 506 of the Revenue Act of 1932, 47 Stat. 169, which imposes a tax upon every transfer of property by gift, "whether the transfer is in trust or otherwise, whether the gift is direct or indirect, and whether the property is real or personal, tangible or intangible; . . ."

The petitioner, age 72, made an irrevocable...

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