BAUR v. COMMISSIONER OF INTERNAL REVENUE

No. 8595.

145 F.2d 338 (1944)

BAUR v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Third Circuit.

Decided September 21, 1944.

Rehearing Denied November 16, 1944.


Attorney(s) appearing for the Case

Thorpe Nesbit, of Philadelphia, Pa. (Hugh Satterlee, of New York City, on the brief), for petitioner.

Helen Goodner, of Washington, D. C. (Samuel O. Clark, Jr., Asst. Atty. Gen., and Sewall Key and J. Louis Monarch, Sp. Assts. to Atty. Gen., on the brief), for respondent.

Before BRATTON and JONES, Circuit Judges, and KIRKPATRICK, District Judge.


JONES, Circuit Judge.

The questions raised by the pending petition for review are (1) whether the donee of a gift of untaxable amount is personally liable, to the extent of the value of the gift, for an unpaid tax on a gift to another donee made by the same donor in the same calendar year and (2) whether such liability, if it exists, may be enforced against the donee, as a transferee, after the statute of limitations has run against the donor's liability, in the absence...

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