Briggs v. Commissioner
United States Tax Court
Held, gifts of stock to infant donees under guardianship, were gifts of present interests in property.
1Opinion of the Court
OPINION.
Tietjens, Judge:
The petitioner contests a deficiency of $5,255.81 in gift tax for 1954, based on a determination by the Commissioner that gifts of stock made by petitioner to nine minor donees under guardianship were gifts of future interests in property rather than present interests.
All of the facts are stipulated and the stipulation of facts together with the pertinent exhibits are incorporated herein by reference.
Petitioner permanently resides in Naples, Florida, where she resided during the taxable year 1954. Her gift tax return for that year was filed with the director of…
2Cases cited8 opinions
- Kieckhefer v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1951
- Stifel v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1952
- Commissioner of Internal Revenue v. SharpCourt of Appeals for the Ninth Circuit · 1946
- Kieckhefer v. CommissionerUnited States Tax Court · 1950
- Stifel v. CommissionerUnited States Tax Court · 1951
3 more not listed; retrieve them via the Exa API.
3Cited by5 opinions
- Messing v. CommissionerUnited States Tax Court · 1967
- Nell K. Ross, Individually and James G. Harris and Elizabeth Ross Harris, Independent of the Estate of James H. Ross, Deceased v. United StatesCourt of Appeals for the Fifth Circuit · 1965
- Briggs v. CommissionerUnited States Tax Court · 1960
- Buck v. CommissionerUnited States Tax Court · 1972
- Messing v. CommissionerUnited States Tax Court · 1967