Cecile Johnson Nelson PREJEAN, Petitioner,
v.
COMMISSIONER OF INTERNAL REVENUE, Respondent.
United States Court of Appeals Fifth Circuit.https://leagle.com/images/logo.png
January 7, 1966.
January 7, 1966.
Attorney(s) appearing for the Case
Oscar Nipper, Houston, Tex., Nipper & Knox, Houston, Tex., for appellant.
Thomas L. Stapleton, Atty., Dept. of Justice, Washington, D. C., John B. Jones, Jr., Act. Asst. Atty. Gen., Lee A. Jackson, Richard M. Roberts, Meyer Rothwacks, Robert N. Anderson, Robert H. Solomon, Attys., Dept. of Justice, Washington, D. C., Mitchell Rogovin, Chief Counsel, Charles Owen Johnson, Atty., IRS, Washington, D. C., for appellee.
Before HUTCHESON, JONES, and BROWN, Circuit Judges.
United States Court of Appeals Fifth Circuit.
PER CURIAM:
This is an appeal from a deficiency determination by the Tax Court.1 During 1960 the taxpayer, Cecile Johnson Nelson Prejean, made a gift in trust and named as beneficiaries of the trust eight persons other than herself. On her gift tax return for 1960 Mrs. Prejean claimed annual exclusions of $3,000 for each of the eight donee-beneficiaries. The Commissioner and the Tax Court disallowed the annual exclusions on the ground...
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