ALLEN v. COMMISSIONER

Docket No. 2505.

3 T.C. 1224 (1944)

VIVIAN B. ALLEN, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated August 15, 1944.


Attorney(s) appearing for the Case

Arthur Garfield Hays, Esq., James R. Cherry, Esq., and Julian G. Culver, Esq., for the petitioner.

William F. Evans, Esq., for the respondent.


This proceeding involves a gift tax deficiency of $7,136.24 for 1941. The questions in issue are (1) whether certain gifts in trust made in the prior years 1933 and 1935 were gifts of future interests, and (2) the value of certain shares of stock transferred to one of the trusts in 1941. Some of the facts have been stipulated.

FINDINGS OF FACT.

Petitioner is a resident of New York, New York. She filed her gift tax return for 1941 with the collector of internal...

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