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SPRINGFIELD NATIONAL BANK v. COMMISSIONER

Docket No. 109966.

4 T.C.M. 211 (1945)

Springfield National Bank, Trustee and Transferee v. Commissioner.

United States Tax Court.

Entered February 10, 1945.

Attorney(s) appearing for the Case

William W. Johnston, C. P. A., 293 Bridge St., Springfield, Mass., for the petitioner. Charles P. Reilly, Esq., for the respondent.

Memorandum Opinion

OPPER, Judge:

The correctness of a deficiency in gift tax for the year 1937 in the amount of $524.53 is placed in issue by this proceeding. The determination against petitioner is the result of respondent's conclusion that it is liable as a fiduciary and transferee for the unpaid gift tax liability of the donor. The sole question in controversy is the existence of that liability, an issue as to the correctness of the tax itself involving...

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