Hooker v. Commissioner of Internal Revenue

SIBLEY, Circuit Judge.

The petitioner, during the year 1943, added to a trust for his minor son property of a value of $159,355. A gift tax was assessed on all of it, except what was determined to be the value of the son’s right to receive the income for his support and education for the year between the date of the transfer and the son’s coming of age. The Tax Court sustained the tax. 10 T.C. 388.

The story briefly told is this: Petitioner Hooker at age twenty-one married, and had a son born April 7, 1923, and a daughter *865born Jan. 14, 1925. She died July 2, 1940. Petitioner and his wife were…