Clinard v. Commissioner
United States Tax Court
A grandfather entered into trust agreements providing for gifts to minor grandchildren which, in the event of death prior to age 21, would pass to the donees' "next of kin" other than the grandfather. Held, the grandfather was not entitled to $ 3,000 gift tax exclusions, since the relevant gifts did not come within the terms of section 2503(c), I.R.C. 1954.
1Opinion of the Court
OPINION
Forrester, Judge:
Respondent has determined deficiencies of $577.50 and $495.75 in petitioner’s gift tax for tbe calendar years 1955 and 1956, respectively. Tbe only issue remaining before us is whether certain gifts of future interests qualify for the $3,000 annual gift tax exclusion under section 2503.1
All of the facts have 'been stipulated and are so found. Those necessary for an understanding of the remaining issue are included herein.
Petitioner, Bernie C. Clinard, is an individual residing at Winston-Salem, Forsyth County, N.C. He filed Federal gift tax returns, Form 709, with the…
2Cases cited7 opinions
- May v. Lewis.Supreme Court of North Carolina · 1903
- Jones v. . OliverSupreme Court of North Carolina · 1844
- Wallace v. . WallaceSupreme Court of North Carolina · 1921
- Williams v. . JohnsonSupreme Court of North Carolina · 1948
- Knox v. . KnoxSupreme Court of North Carolina · 1935
2 more not listed; retrieve them via the Exa API.
3Cited by10 opinions
- Messing v. CommissionerUnited States Tax Court · 1967
- Geraldine Frost Williams and Robert W. Williams v. The United StatesUnited States Court of Claims · 1967
- Estate of Dawson v. CommissionerUnited States Tax Court · 1972
- Ross v. CommissionerUnited States Tax Court · 1979
- Clinard v. CommissionerUnited States Tax Court · 1963
5 more not listed; retrieve them via the Exa API.