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ESTATE OF HOLTZ v. COMMISSIONER

Docket No. 88457.

38 T.C. 37 (1962)

ESTATE OF LEON HOLTZ, DECEASED, PROVIDENT TRADESMENS BANK AND TRUST COMPANY, EXECUTOR, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed April 10, 1962.

Attorney(s) appearing for the Case

Harry T. Devine, Esq., for the petitioner.

Frederick A. Levy, Esq., for the respondent.

DRENNEN, Judge:

Respondent determined deficiencies in gift tax against petitioner for the taxable years 1953, 1954, and 1955 in the amounts of $61,130.90, $22.05, and $8,543.82, respectively.

The issue for decision is whether the transfers in trust of certain property, made by Leon Holtz on June 12, 1953, and January 18, 1955, were completed gifts for purposes of Federal gift tax. The deficiency for 1954 is the result of a technical adjustment dependent...

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