Commissioner of Internal Revenue v. Wells

SPARKS, Circuit Judge.

This review involves an alleged deficiency in gift tax under the Revenue Act of 1932. The facts as found by the Board of Tax Appeals are not disputed.

The taxpayer is an individual, a citizen and resident of the United States. On December 27, 1933, he created three irrevocable trusts,, one for each of his three minor children. Thereafter, within that calendar year, he transferred, without valuable consideration, to each of the three trusts, share and share alike, his entire right, title, and interest in and to certain shares of corporate stock of an aggregate value of…