Cox v. Commissioner
United States Board of Tax Appeals
1. Petitioner transferred $100,000 to a trust, the income to be paid to his son for life, portions of the corpus to be paid to the son when he attained certain ages and the remainder to be paid to transferor's wife or others.
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1. Petitioner transferred $100,000 to a trust, the income to be paid to his son for life, portions of the corpus to be paid to the son when he attained certain ages and the remainder to be paid to transferor's wife or others. Held, that the transfer was not of a future interest in property and petitioner, in computing his gift tax, properly excluded $5,000 from the amount transferred under section 504(b), Revenue Act of 1932. Commissioner v. Wells, 88 Fed.(2d) 339. 2. During the taxable period referred to in the preceding paragraph, petitioner transferred another $100,000 to his wife in trust…
1Opinion of the Court
OPINION.
Mellott :
Tbe Commissioner determined a deficiency in gift tax for the calendar year 1935 in tbe amount of $600.
The proceeding was submitted upon an agreed statement of facts, all of which we find to be as stipulated. Petitioner, a resident of Ardmore, Oklahoma, duly filed a gift tax return for the calendar year 1935, reporting total gifts made during that year of $200,000 and net gifts made during the preceding year of $77,Y91.38. The $200,000 consisted of two gifts of $100,000 each made to trusts. Accordingly petitioner excluded $5,000 from each, under section 504 (b) of the Revenue…
2Cases cited1 opinion
- Anderson v. WilsonSupreme Court of the United States · 1933
3Cited by7 opinions
- Welch v. DavidsonCourt of Appeals for the First Circuit · 1939
- Semanaz de Braegger v. DescartesSupreme Court of Puerto Rico · 1954
- Pelzer v. United StatesUnited States Court of Claims · 1940
- Cox v. CommissionerUnited States Board of Tax Appeals · 1938
- Prejean v. CommissionerUnited States Tax Court · 1964
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