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FIDELITY-PHILADELPHIA TRUST CO. v. COMMISSIONER

Docket Nos. 112781, 112782.

3 T.C. 670 (1944)

FIDELITY-PHILADELPHIA TRUST COMPANY, ALLEGED TRUSTEE AND TRANSFEREE, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. SAMUEL T. BODINE, ALLEGED TRANSFEREE AND DONEE, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated April 26, 1944.

Attorney(s) appearing for the Case

H. Ober Hess, Esq., and William R. Spofford, Esq., for the petitioners.

Myron S. Winer, Esq., for the respondent.

The respondent has determined that the petitioner, Fidelity-Philadelphia Trust Co., is liable, as trustee and transferee of property of William W. Bodine, for a deficiency in gift tax for the calendar year 1938 in the amount of $3,000, plus interest, on gifts made by William W. Bodine during that year. In addition, the respondent has determined that the petitioner, Samuel T. Bodine, as transferee and donee of property transferred by William W. Bodine, is liable for said deficiency...

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