GELLER v. COMMISSIONER

Docket No. 11369.

9 T.C. 484 (1947)

ANDREW GELLER, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated September 29, 1947.


Attorney(s) appearing for the Case

Arthur Richenthal, Esq., for the petitioner.

Fred R. Tansill, Esq., for the respondent.


This case involves deficiencies in gift tax for the years 1943 and 1944, in the respective amounts of $265.03 and $1,704.41. The only question propounded for our determination is whether, in computing net gifts for previous years in calculating the gift taxes for 1943 and 1944, the petitioner is entitled to exclude, under section 1003 (b) of the Internal Revenue Code, $5,000 for each of six gifts in 1938, or whether they were gifts of future interests, and therefore not excludible...

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