LOCKARD v. COMMISSIONER

Docket No. 7921.

7 T.C. 1151 (1946)

BARBARA M. LOCKARD, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated November 14, 1946.


Attorney(s) appearing for the Case

James D. Dow, Esq., for the petitioner.

J. T. Haslam, Esq., for the respondent.


This proceeding involves a proposed deficiency of $5,517.39 in gift tax liability for 1941.

The main issue raises the question as to whether a beneficiary's right to receive the income under a short term trust, the income of which is taxed to the donor under the Clifford case, constitutes a completed gift, or whether the amounts actually distributed to the beneficiary constituted gifts in the year and in the amount received by him. The second question relates...

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