ESTATE OF JARDELL v. COMMISSIONER

Docket No. 48489.

24 T.C. 652 (1955)

ESTATE OF LOUISE JARDELL, DECEASED, ALEC JOHN JARDELL, ADMINISTRATOR, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed July 14, 1955.


Attorney(s) appearing for the Case

Fred H. Sievert, Jr., Esq., for the petitioner.

Robert B. Wallace, Esq., for the respondent.


OPINION.

OPPER, Judge:

A deficiency in gift tax for 1949 of $5,625 is here in issue. The question is whether the subject matter of ten gifts made in that year consisted of future interests so as to preclude the $3,000 exclusions.

All of the facts have been stipulated and they are hereby found. Petitioner's gift tax return for 1949 was filed with the collector of internal revenue for the district of Louisiana.

On October 2, 1949, petitioner...

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