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ROSEN v. C. I. R.

Nos. 12013-12016.

397 F.2d 245 (1968)

Leonard ROSEN, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. Dorothy ROSEN, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. Julius J. ROSEN, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. Claire A. ROSEN, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Fourth Circuit.

Decided June 14, 1968.

Attorney(s) appearing for the Case

Jacquin D. Bierman, New York City, on brief for petitioners.

Mitchell Rogovin, Asst. Atty. Gen., Lee A. Jackson, Robert N. Anderson, and David English Carmack, Attys., Department of Justice, on brief, for respondent.

Before HAYNSWORTH, Chief Judge, and CRAVEN and BUTZNER, Circuit Judges.

CRAVEN, Circuit Judge:

These consolidated appeals are taken from a decision of the Tax Court adverse to the taxpayers/appellants Leonard Rosen, Dorothy Rosen, Julius J. Rosen and Claire A. Rosen. The only issue presented for review is their entitlement to annual exclusions of up to $3,000 per donee in the computation of gift taxes. We hold that the taxpayers are entitled to the exclusions for the years in question, 1961,...

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