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DAVIS v. COMMISSIONER

Docket No. 34213.

22 T.C. 1091 (1954)

MARTHA HUBBARD DAVIS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed August 24, 1954.

Attorney(s) appearing for the Case

Wilson W. Wyatt, Esq., and Edgar A. Zingman, Esq., for the petitioner.

A. Robert Doll, Esq., and John C. Calhoun, Esq., for the respondent.

The respondent has determined a deficiency in gift tax of $48,431.26 for the year 1947. The question presented is whether a gift of $249,250.06 in securities in the taxable year to a trust is deductible as a charitable or educational gift under section 1004 (a) (2) (B) of the Internal Revenue Code of 1939.

FINDINGS OF FACT.

The petitioner is an individual residing at Louisville, Kentucky. She filed a gift tax return...

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