FUNKHOUSER v. COMMISSIONER

Nos. 67616-67632.

17 T.C.M. 1094 (1958)

T.C. Memo. 1958-222

Raymond J. Funkhouser, et al. v. Commissioner.

United States Tax Court.

Filed December 31, 1958.


Attorney(s) appearing for the Case

John S. McDaniel, Jr., Esq., for the petitioners. William Schwerdtfeger, Esq., for the respondent.


Memorandum Findings of Fact and Opinion

The Commissioner has determined deficiencies in the gift tax of Raymond J. Funkhouser for the years 1952 and 1953 in the amounts of $9,411.43, and $2,013.34, respectively. The only question for decision is whether exclusions of $3,000, each, are allowable under section 1003(b), 1939 Code, for gifts made to trusts in the years 1948, 1950, 1951, 1952, and 1953.

Findings of Fact

Raymond J. Funkhouser resided...

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