KELLY v. COMMISSIONER

Docket No. 35676.

19 T.C. 27 (1952)

EDWARD J. KELLY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated October 13, 1952.


Attorney(s) appearing for the Case

William W. Ellis, Jr., Esq., for the petitioner.

Robert J. McDonough, Esq., for the respondent.


OPINION.

OPPER, Judge:

A deficiency in gift tax of $1,483.56 for the year 1947 is in controversy. As originally presented, the case involved the applicability of the exclusion provision of Internal Revenue Code section 1003 (b) (3) to two sets of gifts on the ground that they constituted future interests. All of the facts were stipulated and are hereby found accordingly.

The gift tax return for 1947...

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