Goehner v. Commissioner

Mulroney, Judge:

The respondent has determined deficiencies in the gift tax of each petitioner in the above-consolidated cases for the year 1951 in the sum of $63.76.

The sole issue is whether certain gifts in trust were of “future interests” within the meaning of section 1003 (b) (3) of the Internal Revenue Code of 1939.

findings of fact.

The petitioners, William Goehner and Minnie Goehner, are husband and wife. They have two daughters, Evelyn Walz and Grace Greiff. Grace and her husband, Fred, have three children, Barbara, Gale, and Kenneth, who, at the time of trial, were about 12, 10, and 7…