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METCALF v. COMMISSIONER

Docket No. 17809.

9 T.C.M. 884 (1950)

Rowe B. Metcalf v. Commissioner.

United States Tax Court.

Entered October 11, 1950.

Attorney(s) appearing for the Case

Malcolm H. Frost, Esq., 45 East 17th St., New York 3, N. Y., and Harold B. Tanner, Esq., 15 Westminster St., Providence, R. I., for the petitioner. Thomas R. Wickersham, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

The respondent determined a deficiency of $39,036.05 in gift tax for the year 1944.

The petitioner assigns error in the respondent's inclusion in taxable net gifts for 1944 the amount of $170,500 representing total payments made by petitioner in that year to three trusts theretofore created by him for the benefit of his three children, respectively. In the alternative, petitioner assigns error in the respondent's adjustment...

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