Merritt v. Commissioner

OPINION.

Raum, Judge:

The Commissioner contends that when the petitioners executed the 1932 agreement they made gifts of remainder interests in trust which were subject to tax under section 501 of the Revenue Act of 1932. Petitioners concede for the purposes of argument that the agreement created remainder interests in the stock of Bellemead. They urge, however, that no completed gifts were made which would subject fliem to gift tax because the reservation in the agreement of the right to receive distributions of capital, coupled with their power to cause the corporation to make distributions,…