BABCOCK v. COMMISSIONER

Docket Nos. 110091, 110092.

4 T.C.M. 202 (1945)

Charles H. Babcock, Alleged Donee and Transferee v. Commissioner. Safe Deposit and Trust Company of Baltimore, Alleged Trustee and Transferee v. Commissioner.

United States Tax Court.

Entered February 9, 1945.


Attorney(s) appearing for the Case

John H. Alexander, Esq., 120 Broadway, New York, N. Y., for the petitioners. Chas. P. Reilly, Esq., for the respondent.


Memorandum Findings of Fact and Opinion

KERN, Judge:

These cases involve deficiencies in Federal gift taxes determined by respondent in the amount of $1,537.50. The sole issue is whether petitioners' liabilities for this tax are barred by the statute of limitation, and this issue depends upon whether petitioners are transferees within the meaning of section 1025 (b), I. R. C. The facts were stipulated and are as follows:

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