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CHASE NATIONAL BANK v. COMMISSIONER

Docket No. 48652.

25 T.C. 617 (1955)

THE CHASE NATIONAL BANK OF THE CITY OF NEW YORK, TRUSTEE AND ALLEGED TRANSFEREE OF MARIE ELIZABETH MORAN, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed December 22, 1955.

Attorney(s) appearing for the Case

Thomas A. Ryan, Esq., for the petitioner.

Ellyne E. Strickland, Esq., and Robert J. Cowan, Esq., for the respondent.

Respondent has determined a deficiency in gift taxes against petitioner as transferee of Marie Elizabeth Moran, alleged donor. The principal issues are whether her acquiescence in three separate trusts constituted taxable gifts by her of interests allegedly owned by her in the principal of each trust, and, if so, whether petitioner may properly be proceeded against as transferee. Another issue is whether the value of any gift held to have been made by her should be held to...

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