LEVY v. COMMISSIONER

Docket No. 109393.

1 T.C. 598 (1943)

LEON LEVY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated February 18, 1943.


Attorney(s) appearing for the Case

Louis Levinson, Esq., and Isaac D. Levy, Esq., for the petitioner.

Harry L. Brown, Esq., for the respondent.


The respondent determined a gift tax deficiency against the petitioner for the calendar year 1939 in the amount of $510. The sole question before us is whether the petitioner is entitled to an exclusion of $4,000 under section 504 (b) of the Revenue Act of 1932, as amended by section 505 (a) of the Revenue Act of 1938, for a gift of stock made to one Lynne Frances.

FINDINGS OF FACT.

The petitioner filed a gift tax return for the calendar year 1939 with the...

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