PETERS v. ALSUP

Civ. No. 935.

95 F.Supp. 684 (1951)

PETERS v. ALSUP.

United States District Court D. Hawaii, First Division.

February 23, 1951.


Attorney(s) appearing for the Case

Emil C. Peters, Honolulu, T. H., in pro. per.

Ray J. O'Brien, U. S. Atty., District of Hawaii, Honolulu, T. H., Theron Lamar Caudle, Asst. Atty. Gen., Andrew D. Sharpe and Frederic G. Rita, Sp. Assts. to the Atty. Gen., for defendant.


METZGER, Chief Judge.

1. Introduction

This case presents three questions of law, two of them involving difficult if not abstruse problems relating to the taxability, as gifts, of the relinquishment of certain powers reserved by the settlors of a discretionary trust.

Specifically, the questions are as follows:

1. Is the Commissioner of Internal Revenue barred from reviewing the fair market value of corporate stock, a gift of which was...

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