MAGRUDER, Chief Judge.
In this case we are presented with the troublesome problem of determining to what extent a postnuptial marital property settlement executed in contemplation of divorce is subject to the gift tax. The tax year in question is 1942.
As has often been observed, the gift tax was enacted as a complement to the estate tax, and was designed to safeguard the revenue to be derived from the estate tax by minimizing the opportunities of depleting...
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