No. 88.

324 U.S. 18 (1945)


Supreme Court of United States.

Decided January 29, 1945.

Attorney(s) appearing for the Case

Mr. W.M. Cleaves, with whom Mr. E.E. Townes was on the brief, for petitioners.

Mr. J. Louis Monarch, with whom Solicitor General Fahy, Assistant Attorney General Samuel O. Clarke, Jr. and Mr. Sewall Key were on the brief, for respondent.

MR. JUSTICE RUTLEDGE delivered the opinion of the Court.

In 1935, 1936 and 1937 petitioner, Ella F. Fondren, and her husband, since deceased, created seven separate irrevocable trusts, each in favor of a grandchild of tender years; and each of them made gifts to each trust of corporate stock having the fair market value of $5,975. The donors made gift tax returns for 1937, claiming the statutory exclusion of $5,000 for each gift, and accordingly reported taxable gifts...

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