McLean v. Commissioner
United States Board of Tax Appeals
GIFT - INCOMPLETE WHERE POSSIBILITY OF REVERTER. - A transfer in trust with a possibility of reverter in the grantor is not a completed gift of the entire fund transferred.
1Opinion of the Court
OPINION.
Murdock:
The Commissioner has determined deficiencies in gift taxes and penalties for failure to .file timely gift tax returns, as follows:
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The parties have filed a stipulation of all of the facts, which is hereby adopted as the findings of fact. The petitioners concede that they are liable for penalties for failure to file timely gift tax returns for 1932 and 1933 based upon the deficiencies in tax, if any, due for those years. The respondent now concedes and the petitioners agree that the respondent should have increased the net gifts for the year 1932 by only $4,232.50…
2Cases cited5 opinions
- Helvering v. TaylorSupreme Court of the United States · 1935
- Helvering v. HallockSupreme Court of the United States · 1940
- Estate of Sanford v. CommissionerSupreme Court of the United States · 1939
- Heiner v. DonnanSupreme Court of the United States · 1932
- Rasquin v. HumphreysSupreme Court of the United States · 1939
3Cited by7 opinions
- In Re Lueders'estateCourt of Appeals for the Third Circuit · 1947
- Commissioner of Internal Revenue v. McLeanCourt of Appeals for the Fifth Circuit · 1942
- City Bank Farmers Trust Co. v. CommissionerCourt of Appeals for the Third Circuit · 1947
- Bell v. CommissionerUnited States Board of Tax Appeals · 1942
- Cain v. CommissionerUnited States Board of Tax Appeals · 1941
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