ALDRICH, District Judge.
This is an action to recover a gift tax. The tax was assessed and paid on account of a gift in 1946 by a United States citizen, to his three children, of land situated in the Dominion of Canada. A stipulation of facts has been filed, on which defendant moves for summary judgment. Two questions are presented, — did Congress intend to tax such gifts of foreign land, and did it have the power to?
The statute provides as follows...
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