McCOY v. COMMISSIONER

Docket No. 12208.

6 T.C.M. 1097 (1947)

Louise L. McCoy v. Commissioner.

United States Tax Court.

Entered October 8, 1947.


Attorney(s) appearing for the Case

Lloyd J. Schumacker, Esq., 1400 Fidelity-Philadelphia Trust Bldg., Philadelphia, Pa., for the petitioner. Karl W. Windhorst, Esq., for the respondent.


Memorandum Opinion

MURDOCK, Judge:

The Commissioner determined a deficiency of $1,585.04 in gift tax for 1944. The only issue for decision is whether the gifts were entirely of future interests so that no exclusions are allowable. The facts have been stipulated.

[The Facts]

The petitioner filed a gift tax return for 1944 with the collector of internal revenue for the first district of Pennsylvania. She and her husband, J. Rodman...

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