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SCHWARZENBACH v. COMMISSIONER

Docket No. 2352.

4 T.C. 179 (1944)

MARGUERITE F. SCHWARZENBACH, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated October 9, 1944.

Attorney(s) appearing for the Case

George Whitefield Betts, Jr., Esq., and Holt F. McKinney, Esq., for the petitioner.

F. S. Gettle, Esq., for the respondent.

This is a proceeding to redetermine a deficiency in gift tax for the year 1940, in the amount of $23,855.78. By amended petition, petitioner claims an overpayment of gift tax for the same year in the amount of $6,027.45. The principal issue is whether or not petitioner, by means of a trust executed on May 17, 1940, made a taxable gift of any part of the corpus of the trust. If this question is answered affirmatively, two subordinate...

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