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NEWMAN v. COMMISSIONER OF INTERNAL REVENUE

No. 14112.

222 F.2d 131 (1955)

Lois J. NEWMAN (Formerly Lois J. Senderman), Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Ninth Circuit.

April 29, 1955.

Attorney(s) appearing for the Case

Irell & Manella, Louis M. Brown, Gang, Kopp & Tyre, Milton A. Rudin, Martin Gang, Los Angeles, Cal., Lawrence E. Silverton, Van Nuys, Cal., for appellant.

H. Brian Holland, Asst. Atty. Gen., Fred Youngman, Ellis N. Slack, Meyer Rothwacks, Sp. Assts. to Atty. Gen., Kenneth W. Gemmill, Acting Chief Counsel, I.R.S., Washington, D. C., for appellee.

Before HEALY and FEE, Circuit Judges, and DRIVER, District Judge.

DRIVER, District Judge.

This is a petition to review a decision of the Tax Court adjudging a deficiency in gift tax of $50,079.84. The principal question presented is whether petitioner's gift to her minor daughter was completed in 1943, when the property was transferred in trust for the minor, or in 1946, upon the termination of the trust and distribution of the property to the minor's guardian.

The following is a summary of the findings of the Tax Court...

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