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HOOKER v. COMMISSIONER OF INTERNAL REVENUE

No. 12532.

174 F.2d 863 (1949)

HOOKER v. COMMISSIONER OF INTERNAL REVENUE.

United States Court of Appeals Fifth Circuit.

May 30, 1949.

Attorney(s) appearing for the Case

John C. Parsons, Hartford, Connecticut, for petitioner.

L. W. Post, George A. Stinson, Ellis N. Slack, Helen Goodner, Sp. Assts. to Atty. Gen., Washington, D. C., Theron Lamar Caudle, Asst. Atty. Gen., Charles Oliphant, Chief Counsel, Bur. Int. Rev., Charles E. Lowery, Sp. Atty., Bur. Int. Rev., Washington, D. C., for respondent.

Before SIBLEY, HOLMES, and McCORD, Circuit Judges.

SIBLEY, Circuit Judge.

The petitioner, during the year 1943, added to a trust for his minor son property of a value of $159,355. A gift tax was assessed on all of it, except what was determined to be the value of the son's right to receive the income for his support and education for the year between the date of the transfer and the son's coming of age. The Tax Court sustained the tax. 10 T.C. 388.

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