Early v. Reid

SOPER, Circuit Judge.

The question presented by this appeal is whether one exclusion of $5,000 or nine exclusions aggregating $43,929.40 are allowable under § 504 (b) of the Revenue Act of 1932, 47 Stat. 169, 26 U.S.C.A.Int.Rev. Acts, page 585, in computing the gift tax upon a transfer of real estate by indenture of trust from the taxpayer to trustees for the benefit of his wife, two children and six grandchildren. The several beneficiaries acquired present interests under the trust indenture of a value at least equal to the respective exclusions claimed by the taxpayer. Having paid the tax…