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FRANK v. COMMISSIONER

Docket No. 107828.

3 T.C.M. 1180 (1944)

Arthur A. Frank v. Commissioner.

United States Tax Court.

Entered November 2, 1944.

Attorney(s) appearing for the Case

John E. Hughes, Esq., 385 Dearborn St., Chicago, Ill., for the petitioner. David Altman, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

DISNEY, Judge:

This proceeding involves the redetermination of deficiencies of $166.28 and $270.04 in gift taxes for the respective years 1938 and 1939. Petitioner alleges in his petition that no taxable gifts were made and that he made overpayments of gift taxes in the amount of $1,836.42 for 1938 and $5,693.09 for 1939. By an amended answer, respondent alleges that, as the property represented gifts of future interests...

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