United States v. Pelzer

Decision in this case turns on the question whether certain gifts of property in trust for the benefit of several beneficiaries are gifts of “future interests” which, in the computation of the gift tax, are, by § 504 (b) of the 1932 Revenue Act, 47 Stat. 169, 247, denied the benefit, otherwise allowed, of exclusion from the compu tation to the extent of the first $5,000 of each gift “made to any person by the donor” during the calendar year.

Sections 501 (a) and 502 (1) of the 1932 Act impose for each calendar year a tax upon the net amount of transfers “by any individual ... of property by…