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GRAY v. COMMISSIONER

Docket Nos. 110797, 111344, 111345.

3 T.C.M. 552 (1944)

J. Maurice Gray, et al., as Alleged Trustees and Transferees, v. Commissioner. Elva P. Hammer, as Alleged Transferee, v. Commissioner. Robert Bertram Publicker, a Minor, as Alleged Transferee, by Rose Publicker, His Next Friend, v. Commissioner.

United States Tax Court.

Entered June 7, 1944.

Attorney(s) appearing for the Case

Thorpe Nesbit, Esq., Albert S. Lisenby, Esq., and J. Maurice Gray, Esq., 1240 Land Title Bldg., Philadelphia, Pa., for the petitioners. Myron S. Winer, Esq., for the respondent.

Memorandum Opinion

MELLOTT, Judge:

Petitioners contest the respondent's determinations that they are liable, as transferees of property of Harry Publicker, for gift tax for the calendar year 1937 in the amount of $1,500. The cases were consolidated. The issues are:

(1) Whether proper and sufficient notice of liability as transferees has been given to the trustees;

(2) Whether the statute of limitations has barred the Commissioner from proceeding...

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